Topic · Australia
FBAR for Americans in Australia: super counts too
An everyday transaction account, an offset account against the mortgage and a superannuation balance will clear the FBAR threshold between them without anyone mentioning it.
By Danilson Ramos · Founder, Atamatax
Updated August 2026
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The FBAR is a reporting form with no tax attached, which is exactly why it gets missed. Nothing in Australia prompts it, no Australian institution mentions it, and the amounts involved are ordinary — an everyday account, an offset account sitting against a mortgage, and a super balance that has been accumulating since your first job.
The threshold is worldwide, and it is a maximum
The test is the $10,000 aggregate MAXIMUM across all your non-US financial accounts at any point during the calendar year — not the closing balance, not the average, and not only Australia. And it is a US-dollar threshold, so the arithmetic has to be done in US dollars: A$9,000 is roughly US$6,500, not US$9,000. Someone with A$14,000 in an everyday account and US$4,000 left in an account in another country is over the line, even though neither would be alone.
| Australian account | Reportable? | Note |
|---|---|---|
| Everyday / transaction account | Yes | The ordinary case |
| Offset account against a mortgage | Yes | It is a deposit account, whatever it offsets |
| Term deposit | Yes | Held at a foreign financial institution |
| Superannuation (industry or retail) | Generally yes | Reportable independently of how its income is characterised |
| Self-managed super fund | Generally yes | The fund's accounts, and possibly your authority over them |
| CommSec / Stake / SelfWealth brokerage | Yes | Report the account, not each holding |
| A US-dollar account at an Australian bank | Yes | The currency is irrelevant; the institution's location is not |
Working it out
- For each account, find the MAXIMUM value it reached at any point in the CALENDAR year — not the Australian financial year, and not the closing balance.
- Convert to US dollars at the Treasury year-end rate for that year.
- Add every account together, including any held outside Australia.
- Compare the total to $10,000. If it exceeds that figure, EVERY account is reported — not only those that individually cross it.
- Include accounts you have signature authority over but do not own.
- File FinCEN Form 114 electronically, April 15, with an automatic extension to October 15
If you have never filed
Penalties are $16,536 for non-willful violations and $165,353 where conduct is willful, but the ordinary case of someone who did not know is a compliance problem rather than an enforcement one. The IRS publishes the Delinquent FBAR Submission Procedures where returns are otherwise correct, and the Streamlined Foreign Offshore Procedures where returns are also late.
Check whether you cross the line
Enter your account balances and the free checker shows which reporting thresholds you cross — FBAR, Form 8938, or neither.
Authorities cited
- FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
- IRS Delinquent FBAR Submission Procedures — Delinquent FBAR Submission Procedures — for taxpayers who are not under examination and do not owe additional tax
- IRS Streamlined Foreign Offshore Procedures — U.S. Taxpayers Residing Outside the United States — Streamlined Foreign Offshore Procedures
- IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.
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