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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

Tax review partner: onboarding in progress. This article has not yet been independently reviewed by a credentialed professional — every figure cites its IRS source so you can verify it directly.

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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
The euro-denominated size of an Italian conto corrente is irrelevant on its own. Two accounts and a deposito titoli that peak together above the threshold trigger the filing.

Quadro RW, IVIE and IVAFE are a different system

FBAR (United States)Quadro RW (Italy)
ReportsAccounts held outside the U.S.Assets held outside Italy
Filed withFinCEN, separately from the returnThe Modello Redditi PF
Threshold$10,000 aggregate peakMonitoring obligation with its own rules
Attached taxNone — informationalIVIE on foreign property, IVAFE on foreign financial assets
Does the other satisfy it?NoNo

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 §1010.35031 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. §531431 U.S.C. §5314 — Statutory basis for the FBAR (foreign financial account reporting)
  • IRS Form 8938About Form 8938 — Statement of Specified Foreign Financial Assets
  • IRC §6038DIRC §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.

Frequently asked questions

Do Italian bank accounts count for the FBAR?#
Yes. An Italian conto corrente, deposito titoli, Poste Italiane account or libretto postale is a non-U.S. financial account, and its maximum value during the year counts toward the $10,000 aggregate test.
I already file Quadro RW in Italy — does that cover the FBAR?#
No, and the two point in opposite directions. Quadro RW reports assets you hold outside Italy to the Agenzia delle Entrate; the FBAR reports accounts you hold outside the United States to FinCEN. From Italy, your Italian accounts are the foreign ones for FBAR purposes. Neither filing discharges the other.
What exchange rate applies to euro balances?#
The Treasury Reporting Rates of Exchange for December 31 of the year being reported, applied to each account's maximum euro balance during that year. This is not the IRS yearly-average rate used for income on the Form 1040.
Does a polizza vita or gestione patrimoniale go on the FBAR?#
It depends on the contract. An arrangement with a cash or account-like value held with an Italian institution is commonly reportable; a pure risk policy with no such value is generally treated differently. Because Italian life-insurance wrappers vary considerably, this is worth confirming against the specific policy.
Do I need Form 8938 as well in Italy?#
Possibly. Form 8938 has higher thresholds than the FBAR — for a single filer living abroad, from $200,000 at year end or $300,000 at any point — and covers a broader class of specified foreign financial assets. Crossing the FBAR threshold does not automatically mean crossing the Form 8938 one, and the reverse can also happen.

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