Topic · France
FBAR for Americans in France: which French accounts count, and the mirror rule France runs
The compte courant, the livrets, the PEA, the CTO, the assurance-vie, the PER — all of them toward the $10,000 combined peak, filed with FinCEN, separately from the return. And France asks the same question in reverse.
By Danilson Ramos · Founder, Atamatax
Published June 2026 · Updated November 2026
Part of the France desk — every US tax topic for France in one place.
Check it for your own accounts
Do you need to file an FBAR?
Three questions, no balances typed, no email. The read explains the aggregate rule — the part most people get wrong — and what would settle the rest.
Free, no account, nothing you answer leaves this page. Open the full FBAR / Form 8938 checker
A threshold screen, not a filing determination. Three answers cannot establish whether a specific account is reportable; the full checker and the account's own terms can.
The FBAR is the report Americans in France most often miss, because nothing in French life prompts it and because the ordinary accounts of an ordinary life cross its threshold quietly. A salary account, a Livret A and a PEA opened for the tax break add up to more than ten thousand dollars on most days of the year.
What counts
| French account | FBAR account? | Note |
|---|---|---|
| Compte courant, compte sur livret | Yes | At any bank — BNP Paribas, Société Générale, Crédit Agricole, La Banque Postale, a Crédit Mutuel |
| Livret A, LDDS, LEP | Yes | Regulated savings; the French exemption is irrelevant to the report |
| PEL / CEL | Yes | Savings accounts with a housing-loan right |
| PEA / PEA-PME | Yes | A securities account with a cash sub-account |
| CTO | Yes | Brokerage; Boursorama, Fortuneo, Bourse Direct, a bank |
| Assurance-vie | Yes | A cash-value insurance policy is an FBAR account (31 CFR 1010.350(c)(3)) |
| PER (individual or employer) | Generally yes | A retirement account with a cash value; the treaty status changes the tax, not the report |
| Lydia, a French neobank, Revolut (Lithuanian entity) | Yes | Held by a non-US entity |
| A joint account with a French spouse | Yes | Reported in full; signature authority alone also counts |
| Directly owned property, gold, a car | No | Not financial accounts |
The mirror rule
France has its own version. A French tax resident must declare every account held, opened, used or closed outside France during the year on form 3916 / 3916-bis, attached to the French return, and every foreign life-insurance contract likewise. For an American in France that means the US brokerage account, the US bank account kept for Social Security, the old 401(k) if it is an account — reported to Paris while the French accounts are reported to FinCEN. Neither report is a tax; both carry penalties for silence.
Form 8938, the second report
Form 8938 is filed with the Form 1040 and tests the total of specified foreign financial assets — broadly the same accounts, plus directly held foreign stock and fund units held outside an account — against $200,000 at year-end or $300,000 at any time for a single filer living abroad, and $400,000 year-end for a joint return. The two reports overlap and are both required; neither satisfies the other.
Missed years
If returns were filed and only the FBARs were missed, the late reports are filed with FinCEN with an explanation and a reasonable-cause statement — the IRS withdrew its published Delinquent FBAR Submission Procedures, and their printed no-penalty assurance, on July 1, 2026; penalties remain discretionary and the IRM 4.26.16 examiner standard is unchanged. If returns were missed too, the FBARs travel with the catch-up route — Streamlined Foreign Offshore for a non-willful filer abroad, or something else — and the eligibility checker walks the gates. Never assume the route; the gates decide it.
- List every French (and other non-US) account, including the ones you had forgotten and the joint ones.
- Pull each account's highest balance in the year from the statements — not the year-end balance.
- Convert at the Treasury year-end rate and add them up; if the total exceeded $10,000, every account is reported.
- Run the Form 8938 test on the same list, at the abroad thresholds for your status.
- For past years, decide the route on the facts: late FBAR filing with a reasonable-cause statement if the returns were filed, the catch-up gates if they were not.
Do your French accounts cross the line?
Enter each account's peak as a band; the free checker runs the FBAR aggregate and the Form 8938 test together.
Authorities cited
- 31 U.S.C. §5314 — 31 U.S.C. §5314 — Statutory basis for the FBAR (foreign financial account reporting)
- 31 CFR §1010.350 — 31 CFR §1010.350 — FBAR (FinCEN Form 114) filing requirement and $10,000 threshold
- FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
- IRC §6038D — IRC §6038D — Information reporting of specified foreign financial assets (Form 8938)
- IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
- IRS Delinquent FBAR Submission Procedures (withdrawn 1 July 2026) — Delinquent FBAR Submission Procedures — the IRS page removed on 1 July 2026 (archived copy, last reviewed by the IRS 19 Feb 2026)
- IRS Streamlined Foreign Offshore Procedures — U.S. Taxpayers Residing Outside the United States — Streamlined Foreign Offshore Procedures
- 31 U.S.C. §5321 — 31 U.S.C. §5321 — Civil penalties for FBAR violations (§5321(a)(5))
- Bittner v. United States (2023) — Bittner v. United States, 598 U.S. 85 (2023) — the non-willful FBAR penalty applies per report, not per account
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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