Finance

FBAR and FATCA from Portugal

Every American living in Portugal must file FBAR and (often) FATCA reports each year. Here's exactly what counts, when it's due, what the penalties look like, and how to make both forms a 30-minute job instead of a weekend of dread.

8 min read · Updated 2026-04-30

Why these two forms matter so much

FBAR and FATCA are reporting forms, not tax forms — you don't owe money on them, you just declare what you own abroad. But the penalties for non-filing are out of all proportion to the effort required. A wilful FBAR violation can be punished at up to $100,000 or 50% of the account balance, per year. Even non-wilful FBARs run $10,000 per missed account per year. Portuguese banks have been auto-reporting US-person accounts to the IRS since 2014 under FATCA agreements — pretending these accounts don't exist is no longer a strategy.

FBAR — FinCEN Form 114

The FBAR is the older of the two and the trigger threshold is much lower. File electronically through the BSA E-Filing System — there is no paper version.

  • Trigger: combined high balance across all your non-US accounts crosses $10,000 USD at any single moment during the year
  • Counts: every account you own or have signature authority over — Portuguese bank accounts, Revolut PT IBAN, brokerage accounts, joint accounts, kids' accounts in your name, employer pension accounts in some cases
  • Doesn't count: real estate, crypto self-custody (still grey), US-based accounts
  • Due: 15 April with automatic extension to 15 October — no form to file for the extension
  • Cost: free, takes ~20 minutes if your data is organised

FATCA — IRS Form 8938

Filed alongside your 1040 when your foreign financial assets cross higher thresholds. There's significant overlap with FBAR — most Americans abroad file both — but they go to different agencies and the rules differ in subtle ways.

  • Single filers living abroad: file if foreign financial assets exceed $200,000 on 31 December, or $300,000 at any time during the year
  • Married filing jointly abroad: $400,000 / $600,000
  • Counts: bank accounts, brokerage accounts, foreign mutual funds, foreign pension cash value, cryptocurrency held on foreign exchanges (clarified 2024)
  • Doesn't count: directly-owned foreign real estate, personal property, US-based accounts
  • Penalties: $10,000 per year for failure, plus additional $10,000 per 30 days of continued failure after IRS notice (capped at $50,000)

The data you'll need

Both forms ask for essentially the same information — gathering it once a year saves a lot of pain.

  • Account number and account type (checking, savings, brokerage, pension)
  • Bank's full legal name and complete street address
  • Highest balance during the year, in original currency, with conversion to USD at year-end Treasury rate
  • Type of ownership (sole, joint, signature authority only)
  • For FATCA: maximum value during the year AND value on 31 December

A simple yearly workflow

Build a single spreadsheet you reuse every year. Most expats can complete both forms in under an hour once the template exists.

  • January: download December statements from every Portuguese account
  • January–February: open each statement, find the year's high balance, paste into the spreadsheet
  • Convert balances using the Treasury Reporting Rates of Exchange (treasury.gov) for 31 December
  • March: file FBAR online via bsaefiling.fincen.treas.gov — instant confirmation
  • April: hand the same spreadsheet to your tax preparer for Form 8938 alongside the 1040

What Portuguese banks already report

Under the US-Portugal IGA signed in 2015, every Portuguese bank automatically reports US-person accounts to Portuguese tax authorities, who pass the data to the IRS each year. That report includes your name, address, NIF, account number, year-end balance and gross interest paid. The IRS therefore knows the accounts exist regardless of whether you file. This means: (1) discrepancies trigger letters, and (2) the upside of filing diligently is mostly to avoid the downside of penalties — which is huge.

Special cases worth knowing

A few Portuguese-specific situations trip people up.

  • PPR (retirement savings plans) and Portuguese pension funds are generally reportable on both forms
  • Joint accounts with a Portuguese spouse: report 100% of the high balance on FBAR; FATCA rules are more nuanced
  • Signature authority on a Portuguese employer's account counts for FBAR even if you have no ownership
  • Crypto on Portuguese exchanges (e.g., Coinify, Bitstamp PT entity) is reportable; self-custody crypto is currently outside both regimes (subject to change)
  • Closing an account during the year doesn't exempt you — if the high balance crossed the threshold, you still file