Skip to main content
Next expat filing deadlineCheck my situation
atamatax

Broker · Europe

Wise (TransferWise), the FBAR, and the fund behind 'Interest'

Wise multi-currency balances count toward the $10,000 FBAR aggregate, and the Interest/Stocks features hold your balance in funds — a PFIC question for US taxpayers.

By Danilson Ramos · Founder, Atamatax

Published July 2026 · 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.

Takes ~2 minutes — then continues into your full free diagnostic.

Wise is the default way expats move money between countries — and one of the most commonly forgotten accounts at FBAR time, because it doesn't feel like a bank account.

The balances count

A Wise multi-currency account held with a non-US Wise entity (Belgium for the EEA, the UK for the UK — it depends on your address) is a foreign financial account: every currency balance and jar counts toward the $10,000 FBAR aggregate at its maximum value during the year, and toward the Form 8938 thresholds. Money 'just passing through' still counts on the day it's there.

The fund behind 'Interest' and 'Stocks'

Wise's Assets features work by holding your balance in funds: the Interest option in a money-market fund, the Stocks option in a world-equity index fund. Where those funds are non-US domiciled (the general case for non-US customers), a US taxpayer is looking at a PFIC — Form 8621 territory — behind what the app shows as a balance. Wise restricts these features for US persons in many regions, but pre-existing balances and edge cases exist. Check the fund's name and domicile in the product documents.

Wise featureWhat it isUS filing angle
Currency balances + jarsE-money balancesFBAR + 8938 aggregates
Assets — InterestMoney-market fundLikely PFIC if non-US domiciled → Form 8621
Assets — StocksWorld-equity index fundLikely PFIC if non-US domiciled → Form 8621
Wise US accountUS entity accountNot an FBAR account (but your other accounts are)

What to export

  • Per-currency statements showing the maximum balance during the year.
  • For any Assets balance: the fund name and domicile from the product documents.
  • Year-end balances for the Form 8938 EOY test.

See what your Wise account triggers

Enter your balances — the free checker shows the FBAR / Form 8938 math line by line. Atamatax is tax-preparation software, not a CPA firm, and this is not individualised tax advice.

Entities and product structures vary by your country and change over time — confirm yours in Wise's documents. Atamatax provides preparation software and educational estimates, not individualised tax, legal, or investment 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)
  • IRS Form 8938About Form 8938 — Statement of Specified Foreign Financial Assets
  • IRC §1297IRC §1297 — Definition of a passive foreign investment company
  • IRS Form 8621About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
  • IRC §1291IRC §1291 — Interest on tax deferral (excess-distribution regime)

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 I really have to report a Wise account I only use for transfers?#
Generally yes if it's held with a non-US Wise entity and your combined non-US accounts exceeded $10,000 at any point. The FBAR looks at each account's maximum value during the year — a large transfer that sat in the balance for a day counts at that day's value.
Is Wise Interest a PFIC?#
The Interest feature holds your balance in a money-market fund, and where that fund is non-US domiciled it's generally a PFIC for a US taxpayer. Wise restricts Assets for US persons in many regions, but if you hold or held such a balance, check the fund's domicile in the product documents before filing.
My Wise profile is with the US entity. Do I still have an FBAR issue from it?#
No — an account with Wise's US entity is not a foreign account for the FBAR. Your other non-US accounts (local bank, brokerage, other e-money) still aggregate toward the $10,000 threshold.

Related guides

Free, 2 minutes

Start your free U.S. tax risk check.

Answer a few questions about your situation and get a personalized risk summary plus next steps by email.