In short
- You file an FBAR (FinCEN Form 114) when the combined highest balances of all your foreign accounts pass $10,000 at any time during the year, even for a day.
- Accounts you can sign on count too, such as a company account of your SpA, even if the money is not yours.
- The FBAR is due April 15 with an automatic extension to October 15. It is filed online with FinCEN, not with your tax return.
- Form 8938 is a separate IRS form. For people living abroad it applies above $200,000 at year end or $300,000 at any time ($400,000 and $600,000 for joint filers).
- Many accounts go on both forms. Filing one does not replace the other.
Do I need to report my Chilean bank accounts?
If the accounts together ever pass $10,000 in a year, yes. A U.S. person, meaning a citizen, green card holder or U.S. tax resident, files an FBAR when the combined maximum values of all foreign financial accounts exceed $10,000 at any point in the calendar year. You add up each account's highest balance, even if the peaks happened on different days. One week with a large transfer is enough.
The FBAR is not a tax. It reports where your money is. Most people in Chile who file it owe nothing extra because of it.
Which Chilean accounts count?
Almost every account held at a Chilean financial institution counts, including:
- Bank accounts: cuenta corriente, cuenta vista, CuentaRUT at BancoEstado, savings accounts.
- Investments: brokerage accounts, fondos mutuos, time deposits (depósitos a plazo).
- Retirement and savings: voluntary savings such as APV and cuenta 2. How to treat the mandatory AFP account is covered in our AFP and APV guide.
- Accounts you can sign on: for example your SpA's or employer's account, if you have signature authority, even with no money of your own in it.
- Joint accounts: with a spouse or relative. Each U.S. owner reports the full balance.
How and when do I file the FBAR?
The FBAR (FinCEN Form 114) is filed online through FinCEN's BSA E-Filing system, separately from your tax return. It is due April 15 for the previous calendar year, with an automatic extension to October 15. No request is needed.
For each account you report the institution, the account number, and the maximum value during the year, converted to dollars using the Treasury's year-end exchange rate. Bank statements or a year-end certificate from your Chilean bank usually give you what you need.
What is Form 8938 and when does it apply?
Form 8938 comes from FATCA and is attached to your IRS tax return. It covers "specified foreign financial assets", which overlap with FBAR accounts but also include some assets that are not accounts. For taxpayers living abroad, it applies when these assets exceed:
- Single or married filing separately: $200,000 on the last day of the year, or $300,000 at any time.
- Married filing jointly: $400,000 on the last day of the year, or $600,000 at any time.
It only applies if you have to file a U.S. tax return that year. If you meet both thresholds, you file both forms.
What happens if I never filed an FBAR?
Penalties can be serious, but the response depends on why the forms were missed. After the U.S. Supreme Court's 2023 Bittner decision, non-willful FBAR penalties apply per report, per year, not per account. Willful violations are treated far more harshly. If you simply did not know, there are IRS procedures to catch up with reduced or no penalties. See catching up on U.S. returns before filing old reports on your own.
What to organize
A list of your accounts by type and bank, who owns or can sign on each, the years involved, and whether you ever filed FBARs or Forms 8938. Keep account numbers and balances out of any first email or public form. We collect them later through a secure portal.
Common questions
Is the $10,000 per account or in total?
In total. You add up the highest balance of every foreign account during the year. If that sum passes $10,000, you report all the accounts, including small ones.
Does my CuentaRUT count for the FBAR?
Yes. A CuentaRUT is a deposit account at BancoEstado, a foreign financial institution for U.S. purposes, so it counts toward the $10,000 total and is listed on the FBAR.
I only have signing authority on my company's account. Do I report it?
Generally yes. Signature authority over a foreign account is reportable on the FBAR even when the money belongs to the company. It does not go on Form 8938 unless you also have an interest in it.
Do I pay tax because I file an FBAR?
No. The FBAR only reports accounts. Tax is due on the income those accounts earn, such as interest, which goes on your regular return.
Can I file the FBAR myself?
Yes. It is filed free online through FinCEN's BSA E-Filing system. If earlier years are missing, it is worth getting advice first, because how you file late affects penalties.
General information, not individual U.S. or Chilean tax advice. Rules, thresholds and deadlines change; confirm them for your situation. Chile US Tax is an independent practice, not a government office.