FBAR for Americans living in Denmark

Denmark is a near-cashless, account-dense country: a NemKonto for public payments, a lønkonto for salary, a budgetkonto, often an Aktiesparekonto and a brokerage account, plus pension arrangements. Each of those is a candidate foreign financial account for U.S. reporting, and the FBAR test adds them together.

When does an American in Denmark have to file an FBAR?

Generally, when the combined maximum value of all your non-U.S. financial accounts exceeded $10,000 at any point during the calendar year. It is the peak, not the year-end balance, and it is measured across every account you own or can sign for — not account by account.

Which Danish accounts typically count

• Bank accounts at Danske Bank, Nordea, Jyske Bank, Sydbank, Nykredit, Arbejdernes Landsbank, Lunar or Coop Bank — including a NemKonto and a budgetkonto
• Brokerage accounts at Saxo Bank, Nordnet or a Danish bank's investment platform
• An Aktiesparekonto, which is a Danish account holding securities, not a tax wrapper the IRS recognises
• Many pension arrangements held with a pension company or bank, where you have an account-like interest
• Accounts you do not own but have signature authority over — a Danish employer account, an association's account, or a parent's account you can sign for

How to convert kroner to dollars for the FBAR

The FBAR uses the Treasury Reporting Rates of Exchange for December 31 of the reported year — not the IRS yearly-average rate your Form 1040 uses for income. Take each account's maximum DKK balance during the year and convert it at that single year-end rate. Using the yearly average here is one of the most common technical errors on a Danish FBAR.

The FBAR is not Form 8938, and neither is Danish

Danish tax reporting runs on its own track. Skattestyrelsen pre-populates your årsopgørelse from information Danish institutions send it; that has no bearing on whether you owe FinCEN a report. Many Americans in Denmark file both the FBAR and Form 8938, and the two overlap without being the same.

What Danish banks already report about you

Denmark and the United States have a FATCA intergovernmental agreement, so Danish financial institutions identify U.S. account holders and report them. If a Danish bank has asked you to confirm U.S. status or complete a W-9, that is the mechanism. It means the account information is already moving, which is worth knowing before deciding what to do about past years.

What to gather

• Each institution's name and address, and the account number
• The maximum value in DKK during the year — most Danish banks show this in netbank under årsoversigt
• Whether the account is owned, jointly owned, or only signature authority
• The December 31 Treasury rate for DKK for that year