FBAR Reporting for US Companies With Foreign Accounts

The FBAR threshold sits at $10,000 in aggregate value across all foreign financial accounts at any point during the year, not a per-account amount: say five accounts each holding smaller balances add up to more than that on a single day, that combined total still triggers the requirement. The filing is required of both the entity and, separately, any individual with signature authority over the accounts, even if they don't own the funds.

This catches operations leaders and finance staff who have signature authority on a foreign payroll or operating account but no personal ownership stake in it. They may have their own individual filing obligation, distinct from the company's.

Build a list that includes every foreign account the company owns, plus every foreign account any employee has signature authority over on the company's behalf: an EOR-managed local payroll account, a foreign bank account tied to a subsidiary, a joint venture account. Ownership and signature authority are tracked separately for FBAR purposes, and missing the signature-authority category is one of the most common gaps.

Update this list whenever a new foreign entity, EOR relationship, or bank account is opened, rather than reconstructing it once a year from memory when the filing deadline approaches.

For example, a company opens a local payroll account in a new country through its EOR, and a finance manager is given signature authority so they can approve transfers. The company's account list should now include that account, and the finance manager should be told they may have an individual filing obligation separate from the company's. Neither step is likely to happen on its own, because nothing in daily operations flags it. Add a checkpoint to the new-country launch checklist that asks who opened any account, who can sign on it, and whether it belongs on the FBAR list.

FBAR filings are due annually, aligned with the individual tax filing deadline, with an automatic extension available that doesn't require a separate request. Missing the deadline entirely, rather than filing late under the extension, is what creates the real exposure, since the extension exists specifically to avoid that outcome.

Build the FBAR filing into the same calendar reminder system you use for other annual tax deadlines, rather than treating it as a separate, easy-to-forget obligation that only your accountant tracks.

A few patterns that show up repeatedly:

• Assuming only the company needs to file, and missing that individuals with signature authority have their own separate obligation
• Not tracking accounts opened by an EOR or local payroll provider on the company's behalf as foreign accounts
• Waiting until an account balance looks large before considering whether the aggregate threshold across all accounts has already been crossed
• Treating FBAR as a one-time setup task instead of an annual filing tied to the current list of accounts and signatories

Most of these come from treating foreign accounts as someone else's problem to track, usually the EOR's or the bank's, when the filing obligation is actually the company's and the individual's.

Treat the FBAR filing the same way you'd treat any other recurring compliance deadline: one owner, a documented list of accounts and signatories reviewed at least annually, and a calendar reminder tied to the actual deadline, not a vague sense that your accountant handles it. Deel and Rippling both manage local payroll accounts in the countries where they operate on your behalf, which is worth confirming specifically against your FBAR account list rather than assuming it's already covered.

Check with your accountant or a tax attorney on the specific filing mechanics for your situation, since the process and any penalties for a missed filing depend on the individual facts involved.