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FBAR FinCEN Form 114

FBAR (Foreign Bank Account Report, FinCEN Form 114) is the US Treasury requirement for US persons with foreign bank accounts above $10,000. It does NOT apply to non-resident Wyoming LLC owners.

Answer

FBAR is the FinCEN reporting requirement for US persons (citizens and tax residents) with foreign bank accounts whose aggregate value exceeded $10,000 at any point during the year. It does NOT apply to non-resident Wyoming LLC owners because the form is for US persons only. Your Wyoming LLC's US bank account at Mercury, Relay, or Wise Business is a US account, not foreign, so it does not trigger FBAR. Non-residents do not file FBAR regardless of their foreign bank account holdings.

By Zawwad, Founder & CEO, WyomingLLC by Topslice LLC.

Last updated May 20, 2026

Who must file FBAR

  • US citizens (regardless of residence)
  • US green card holders
  • US tax residents
  • US persons with signature authority over foreign accounts
  • Aggregate foreign account balance over $10,000 at any point in the year

Who does NOT file FBAR

  • Non-resident aliens (most Wyoming LLC owners)
  • Foreign-owned US LLCs (the LLC is a US entity)
  • US persons with foreign account balances under $10,000 aggregate

If you become a US person

If you relocate to the US and become a tax resident, FBAR may apply to your foreign bank accounts. File electronically via FinCEN BSA E-Filing System. Due April 15 (automatic extension to October 15). Penalties for non-filing can be substantial, particularly for willful violations.

Frequently asked questions

Does FBAR apply to non-resident Wyoming LLC owners?
No. FBAR is for US persons only.
Does my Wyoming LLC's bank account count as foreign?
No. Mercury, Relay, and Wise Business accounts are US accounts. FBAR is for accounts OUTSIDE the US.
What if my LLC has a foreign bank account?
If you became a US person and the LLC has a foreign account where you have signature authority, FBAR may apply. Consult a US CPA.
What is the FBAR threshold?
$10,000 aggregate across all foreign accounts at any point during the year.

Related guides

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