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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

Part of the Italy desk — every US tax topic for Italy 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

Are you a US person?

A US citizen, a green-card holder, or a US resident for the year.

Do you have financial accounts outside the US?

Bank, savings, brokerage, a pension with a cash value, a fintech balance held by a non-US entity.

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.

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 §1010.350 — 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.

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.

Related guides

Preparation · price before you start

If you want the return and the account reporting prepared

Which route fits depends on a few facts, not on the balances. These are the common situations and the route the same rules give each one. Nothing is charged until you generate a package or accept a written quote.

  1. Returns up to date, accounts over the thresholds, no non-US funds

    Simple · $299 · Self-serve preparation

    The threshold is met and no non-US fund is in play: the Simple package prepares the return with the FBAR and Form 8938 logic inside it.

    What arrives, who prepares and checks it, and who files

    A draft filing package for one tax year: Form 1040 and the supported schedules, Form 1116 inputs, FBAR/Form 8938 threshold logic and filing instructions — with every assumption disclosed.

    The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.

    Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.

    You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.

    Start a Simple return
  2. Every return was filed; only the FBARs were missed

    Simple · $299 · Self-serve preparation

    Your returns appear current and only FBARs were missed. Late FBARs are filed with FinCEN directly, with the reason for filing late and a reasonable-cause statement, so the annual package covers the return side. The threshold is met and no non-US fund is in play: the Simple package prepares the return with the FBAR and Form 8938 logic inside it.

    What arrives, who prepares and checks it, and who files

    The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.

    Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.

    You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.

    Start a Simple return
  3. The accounts hold non-US funds or ETFs

    PFIC Portfolio · $499 · Self-serve preparation

    Non-US funds mean Form 8621 wherever a holding is a PFIC. The PFIC package screens each one from its domicile and drafts the form only where it applies.

    What arrives, who prepares and checks it, and who files

    Everything in Simple plus up to 25 supported Forms 8621 with QEF / mark-to-market / §1291 inputs per holding, fund-domicile classification with confidence shown, and the assumption log — for one tax year.

    The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.

    Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.

    You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.

    Prepare my PFIC portfolio
  4. Returns are missing too, not only the FBARs

    Streamlined Essential · $1,590 · Scoped by hand

    Wages, pensions or bank accounts with no non-US funds is the standard catch-up scope: three returns, six FBARs, and the certification package.

    What arrives, who prepares and checks it, and who files

    A Streamlined Foreign Offshore preparation package: up to three delinquent returns and six FBAR years as worksheets mapped to each year's official forms (official PDFs for the current filing year), a document completeness check, the Form 14653 organiser, and filing instructions — one scoped quote, one payment.

    A person at Atamatax prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures. You write your own statement of facts.

    A person at Atamatax checks the package for completeness before release — an operational check, not a review by a credentialed tax professional. No EA or CPA review is included unless your written scope names one.

    You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.

    Get a scoped quote

When a professional's judgment is needed. Missed years beyond the FBARs, a foreign pension whose US treatment is unsettled, or an IRS letter about the accounts are read by a person before a route is chosen — the account reporting is the easy part; what the accounts earned is the part that needs judgment.

In every route the signatures and the filing stay with you or the accountant you choose; nothing is filed on your behalf. Written questions to hello@atamatax.com get a reply within one business day. Who does what in each route.

Free preliminary result · a few questions

See which foreign-account filings may apply to you

The FBAR and Form 8938 have different thresholds, different definitions and different penalties. A few questions show which one — or both — your accounts point at, and what else rides along.

Check my foreign-account filingsNo signup. Answers stay yours.

Your next step · free

Do your accounts cross the threshold?

Enter each account's highest balance as a band. The checker runs the FBAR aggregate and the Form 8938 threshold for your filing status and where you live, and says which form — or both — the numbers point at. Free, no account.

Get started free