Topic · Italy
FBAR for Americans living in Italy
Italy has its own foreign-asset monitoring regime, and it is not the FBAR. Filing Quadro RW does nothing for FinCEN, and vice versa.
By Danilson Ramos · Founder, Atamatax
Updated August 2026
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Americans in Italy tend to meet the FBAR the wrong way round: they already know Quadro RW, the section of the Modello Redditi that reports assets held outside Italy, and assume the U.S. must have something equivalent that they have already satisfied. They have not. The FBAR reports accounts held outside the United States — which, from Rome, means the Italian ones.
The test
File FinCEN Form 114 for a 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 across accounts and a peak across the year — not a year-end snapshot, and not a per-account threshold. The same figure applies whether you file single or jointly.
Which Italian accounts count
- A conto corrente at Intesa Sanpaolo, UniCredit, BPER, Banco BPM, Fineco, Illimity or a credit union
- A deposito titoli or conto titoli holding securities
- Poste Italiane accounts, including a libretto postale and BancoPosta
- Digital accounts with an Italian or EU IBAN — Fineco, Widiba, Hype, Revolut's EU entity, N26
- A gestione patrimoniale or polizza vita with an account-like value, depending on the contract
- Accounts you can sign for but do not own — an employer's, an association's, a family member's
Quadro RW, IVIE and IVAFE are a different system
| FBAR (United States) | Quadro RW (Italy) | |
|---|---|---|
| Reports | Accounts held outside the U.S. | Assets held outside Italy |
| Filed with | FinCEN, separately from the return | The Modello Redditi PF |
| Threshold | $10,000 aggregate peak | Monitoring obligation with its own rules |
| Attached tax | None — informational | IVIE on foreign property, IVAFE on foreign financial assets |
| Does the other satisfy it? | No | No |
An American living in Italy with a U.S. brokerage account and an Italian salary can end up on both sides of this mirror at once: Quadro RW for the U.S. account, FBAR for the Italian ones. Neither filing is evidence for the other.
Converting euro to dollars
Use the Treasury Reporting Rates of Exchange for December 31 of the reported year, applied to each account's maximum euro balance during that year. Your Form 1040 income uses the IRS yearly-average rate; the FBAR does not. Mixing the two is the most common technical error on an Italian FBAR.
FBAR versus Form 8938
The FBAR goes to FinCEN and starts at $10,000. Form 8938 goes with your Form 1040 and, for a single filer living abroad, starts at $200,000 at year end or $300,000 at any point. Form 8938 also covers a broader class of assets — some Italian holdings appear there that would not appear on the FBAR. Many Americans in Italy file both.
What to collect
- Institution name and address, plus the IBAN or account number
- Maximum euro value during the year — Italian banks show this in the estratto conto or on request
- Ownership: sole, joint, or signature authority only
- The December 31 Treasury EUR rate for that year
Test your Italian accounts against both thresholds
Enter 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.