Topic · Germany
FBAR for Americans living in Germany
Girokonto, Tagesgeld, Depot, Bausparvertrag — which German accounts count toward FinCEN 114, and why the Freistellungsauftrag has nothing to do with it.
By Danilson Ramos · Founder, Atamatax
Updated August 2026
Part of the Germany desk — every US tax topic for Germany in one place.
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German banking spreads a person across accounts by design: a Girokonto for daily life, a Tagesgeldkonto for savings, a Depot for investments, often a Bausparvertrag, sometimes a second bank because the first one's card was inconvenient. Each is a foreign financial account for U.S. purposes, and the FBAR adds them all together.
The test
File FinCEN Form 114 for any year in which the combined maximum value of all your non-U.S. financial accounts exceeded $10,000 at any point. It is an aggregate, and it is the peak rather than the 31 December balance. Signature authority counts even where you own nothing.
Which German accounts typically count
- Girokonto at Sparkasse, Volksbank, Deutsche Bank, Commerzbank, ING, DKB, comdirect or N26
- Tagesgeld and Festgeld savings accounts
- A Depot at Trade Republic, Scalable Capital, Consorsbank, flatex, comdirect or a Sparkasse
- Bausparvertrag with a Bausparkasse, where it holds a credit balance
- Kapitallebensversicherung or a Rürup/Riester contract with an account-like value, depending on the arrangement
- Accounts with Vollmacht or signature authority — an employer's, a Verein's, a relative's
What Germany does not do for you
German banks apply Abgeltungsteuer at source, and a Freistellungsauftrag exempts investment income up to the Sparerpauschbetrag from that withholding. Both are German mechanisms, settled inside the German system. Neither creates, satisfies, or affects a U.S. reporting obligation. Nor does filing a Steuererklärung with your Finanzamt, or receiving a Steuerbescheid.
FBAR versus Form 8938
| FBAR (FinCEN 114) | Form 8938 (FATCA) | |
|---|---|---|
| Filed with | FinCEN, via BSA E-Filing | Your Form 1040 |
| Threshold | $10,000 aggregate peak | From $200,000 year-end / $300,000 peak, single filer abroad |
| Scope | Financial accounts | Specified foreign financial assets — broader |
| German counterpart | None | None |
Germany and the United States exchange account information under a FATCA intergovernmental agreement, which is why a German bank may have asked you to confirm U.S. status or sign a W-9. The information moves whether or not you file.
Converting euro
Use the Treasury Reporting Rates of Exchange for December 31 of the year reported, applied to each account's maximum euro balance during that year. Income on the Form 1040 uses the IRS yearly-average rate instead — the two are not interchangeable.
What to gather
- Bank name and address, plus IBAN
- Maximum euro value during the year — the Jahressteuerbescheinigung and Kontoauszüge together usually give it
- Ownership: sole, joint, or Vollmacht only
- The December 31 Treasury EUR rate for the year
Test your German accounts against both thresholds
Enter your balances and filing status and the free checker shows whether FinCEN 114, Form 8938, or both apply. Educational, not individualised tax advice.
Authorities cited
- 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)
- 31 U.S.C. §5314 — 31 U.S.C. §5314 — Statutory basis for the FBAR (foreign financial account reporting)
- IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
- IRC §6038D — IRC §6038D — Information reporting of specified foreign financial assets (Form 8938)
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.
Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.