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Does my Revolut or Wise account need reporting?
Check the legal entity named in your account statement or in the app's legal documents — Revolut customers are held by different entities depending on where they signed up, and a US-entity account is not a foreign account at all.
The highest point it reached at any time — not the balance today. A band only, and nothing you enter leaves your browser unless you ask for the result by email.
Why the app's name does not answer this
"Is Revolut a foreign account?" has no answer as asked, because Revolut is not one institution. Revolut and Wise both operate a US entity alongside several non-US ones, and two people running the same app on the same phone can be customers of different legal entities depending on where they onboarded. One of them holds a foreign financial account; the other does not. The IBAN prefix is not the test, the currency of the balance is not the test, and your own country of residence is not the test either — the entity holding the money is.
The second thing the app's name hides is what sits inside it. A payments balance raises a reporting question. A savings, interest or investing product attached to the same account can raise a PFIC question, which is a different and considerably more expensive problem: a non-US fund generally needs its own Form 8621 for each year it is held, under a default regime designed to be punitive. Several products marketed as savings pay their return by holding a fund on your behalf, which is exactly the thing Form 8621 asks about.
So this screen reports four questions separately and labels each one with what the facts you gave can actually support. Where they cannot support a conclusion it says needs review rather than choosing the comfortable answer. Nothing here is a determination, and no result decides your filing position — the FBAR and Form 8938 checker runs the thresholds across all your accounts, and the PFIC checker takes a specific fund further.
Common questions
- Do I have to report my Revolut account on an FBAR?
- It depends on which Revolut entity holds your money, and that is not something the app tells you on the front screen. Revolut operates a US entity as well as several non-US ones, and a customer who signed up in the US is held by a US institution — which is not a foreign financial account at all. If a non-US entity holds it, the account counts toward the $10,000 FBAR aggregate, measured at the highest balance during the year across every non-US account you hold or can sign for. Your account statement names the entity.
- Does Wise count as a foreign bank account?
- Same test, same answer: the entity holding the balance decides it, not the currency of the balance and not where you live. Wise holds customers through several entities, and your statement names yours. A Wise account used only to move money between currencies is still a reportable account if a non-US entity holds it and the aggregate threshold is crossed — how you use the account does not change whether it is reportable.
- Is Revolut Savings or Wise Interest a PFIC?
- Possibly, and this is the question the FBAR conversation usually hides. Savings and interest products often pay their return by holding a money-market or similar fund on your behalf, and a fund that is not US-domiciled is generally a PFIC — which means Form 8621, potentially one per fund per year, under a punitive default regime. What decides it is where the fund is domiciled, not the app you bought it through. Ask what the product actually holds.
- What if I do not know which entity holds my account?
- That is the most common honest answer, and this checker treats it as an open question rather than assuming either way. An unknown entity is not a US entity — it is a fact that has to be established before anything else can be answered. Your account statement or the app's legal documents name it.
- I have never filed a US return from abroad. Where does that leave me?
- The account question is about the current year only; missed years are a separate route. The IRS has defined procedures for taxpayers abroad whose failure to file was non-willful, with their own eligibility criteria. Atamatax does not determine willfulness and does not certify eligibility — the Streamlined checker reviews the published criteria against your answers so you can see where you may stand.
Before you rely on this result
What would settle it, and what covers it
Documents or facts needed
- • The account statement naming the legal entity that holds the balance
- • The highest balance the account reached at any point in the year
- • The same for every other non-US account, since the FBAR test aggregates them
- • What any savings, interest or investing product inside the account actually holds
Where this leads
Simple · $299 — prepares the return and FBAR worksheet the account belongs to.
Also possible: PFIC Portfolio ($499) · CPA Export ($199) · Streamlined ($1,590–$2,990+ · scoped quote after the free diagnostic). The cheapest route that covers your facts is the right one; a package never covers more than one tax year.
How to read a status
- Likely:
- The facts entered meet the published test; confirm the inputs before acting.
- Possible:
- Some facts point this way and others are missing; more information decides it.
- Needs review:
- Software cannot settle it from these inputs; a person should look before filing.
- Not currently indicated:
- Nothing entered triggers it this year; a changed fact can change the answer.
- Outside supported scope:
- Atamatax does not prepare this; the result routes to a professional.
Limits. Screens the published tests against the entity, balance band and products you describe. It cannot see which entity holds your account or what a savings product holds — both are stated by you, and both change the answer. Atamatax is tax-preparation software, not a CPA firm, enrolled agent or law firm; it does not transmit returns or FBARs and does not give individualized tax advice.
Tool: /tools/fintech-account-checker
How Atamatax calculations are produced — the tests applied, statutory sources and review cadence — is documented in the methodology, and what is and is not reviewed in accuracy & review. Calculation fixes are recorded in the changelog.
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)
- IRC §1297 — IRC §1297 — Definition of a passive foreign investment company
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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