FBAR Rules for Foreign Crypto Accounts in 2025: What U.S. Taxpayers Must Know

FBAR Rules for Foreign Crypto Accounts in 2025: What U.S. Taxpayers Must Know May, 29 2025

FBAR Crypto Threshold Calculator

What is the $10,000 Threshold?

FBAR requires reporting if your combined value of foreign financial accounts (including crypto exchanges) exceeds $10,000 at any time during the calendar year. Aggregated value across all foreign exchanges counts toward this threshold.

Important: This threshold applies to the maximum value of your holdings during the year, not the current balance.
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Add your holdings from different exchanges to determine if you exceed the $10,000 threshold.

Results

Enter your holdings to see if you exceed the $10,000 threshold.

Aggregated Value: $0.00
Not triggered The $10,000 threshold applies to your combined foreign accounts during the year.

Next Steps

If your value exceeds $10,000, you must file an FBAR.

U.S. taxpayers with crypto holdings on overseas exchanges suddenly find themselves in a reporting maze that looks a lot like the one for foreign bank accounts. Since FinCEN’s 2020 announcement, the FBAR cryptocurrency reporting requirement has been solidified, meaning the old belief that virtual currencies were exempt is now history. If you’ve ever wondered whether your Binance or KuCoin balance triggers a filing, this guide walks you through the rules, the numbers, and the steps you need to stay on the right side of the IRS.

What Triggers an FBAR for Crypto?

FBAR (FinCEN Form 114) requires you to report any foreign financial account that, taken together, exceeds $10,000 at any point during the calendar year. The definition of a "foreign financial account" now explicitly includes Foreign Cryptocurrency Account. That means if you own crypto on a non‑U.S. exchange, the balance counts toward the $10,000 threshold.

  • All accounts are aggregated-your Binance, KuCoin, Bitfinex, and even a foreign‑based wallet provider count together.
  • The threshold is reached the moment your combined holdings hit $10,001, even if it’s just for a single day.
  • The rule applies whether you own the crypto outright or have a contractual right to withdraw it.

In practical terms, a single spike in Bitcoin price can push a modest portfolio over the limit, obligating you to file.

Key Dates and Deadlines for 2025

The filing calendar hasn’t changed with the crypto inclusion:

  1. Original deadline: April 15, 2025.
  2. Automatic extension to October 15, 2025, if you need more time.

Both dates are firm; the IRS does not grant further extensions unless you qualify for a reasonable‑cause waiver.

Valuation: How to Calculate the Maximum Value

Because crypto prices swing wildly, the IRS demands you report the "maximum value during the year" in U.S. dollars. Here’s a practical way to get it right:

  • Pick a reliable source-CoinMarketCap, CoinGecko, or the exchange’s own price feed.
  • Capture the daily high for each asset on each exchange. Many tax‑tracking tools (like Koinly or CoinLedger) can automate this.
  • Convert each daily high to USD using the same source you chose, then sum across all accounts.

If the sum tops $10,000 on any day, you must file. The methodology must be consistent; switching sources mid‑year can raise red flags.

Computer screen showing BSA E‑Filing form with a checklist of five icons and a hand clicking submit.

Gathering the Required Information

The FBAR asks for five data points per account:

  1. Name on the account.
  2. Account number (or a unique identifier if the exchange doesn’t use traditional numbers).
  3. Name and address of the foreign institution (the exchange’s legal entity and headquarters).
  4. Type of account (e.g., "cryptocurrency exchange account").
  5. Maximum value during the year (in USD).

For most major exchanges-Binance, KuCoin, Bitfinex, Bitstamp-you can pull this data from the account statements section or request a formal statement via support.

Filing the FBAR: Step‑by‑Step

Unlike most tax forms, the FBAR is filed electronically through the BSA E‑Filing System. No paper copy, no filing with your regular tax return.

  1. Create a BSA E‑Filer account if you don’t already have one (the process is free and takes about 10 minutes).
  2. Log in and select “File FBAR - FinCEN Form 114.”
  3. Enter the required details for each foreign crypto account. The system will automatically calculate the aggregate value.
  4. Submit the form. You’ll receive an electronic acknowledgment within 24 hours.
  5. Keep the acknowledgment and all supporting records for at least five years from the filing deadline.

If you’re filing under an ITIN instead of an SSN, the IRS explicitly allows it, so don’t let a missing SSN stop you.

Penalties, Enforcement, and How to Fix Past Mistakes

Non‑compliance can be costly. The latest guidance from Dimov Tax warns of penalties up to $16,536 per unreported account per year, and there’s no statute of limitations on FBAR violations. That means an unfiled crypto account from 2018 could still be pursued today.

Fortunately, the IRS offers a path to mitigate damage:

  • Voluntary disclosure. File the missing FBARs as soon as you become aware. The sooner you act, the more likely you’ll avoid the maximum penalty.
  • Streamlined Filing Compliance Procedures. If you’re not under audit and your failure was non‑willful, you may qualify for reduced penalties.
  • Seek professional help. Enrolled agents and CPAs familiar with BSA reporting can file on your behalf and ensure you meet the record‑keeping rules.

Remember, the cost of a penalty far outweighs the time spent gathering statements and filing on time.

Scale balancing crypto coins against a penalty dollar sign, with calendar dates and a shield icon.

Comparison: FBAR vs. FATCA vs. Form 8938

Key Reporting Differences for U.S. Taxpayers
Requirement Threshold (USD) Filing Method Typical Accounts Covered
FBAR (FinCEN Form 114) $10,000 aggregate Electronic via BSA E‑Filing Foreign bank, investment, and crypto accounts
FATCA (Form 8938) $50,000 (single) / $100,000 (married filing jointly) - higher if living abroad Attached to Form 1040 Foreign financial assets, including crypto held at foreign custodians
Form 8938 (Separately filed) Same as FATCA thresholds Part of annual tax return Specified foreign assets, including certain crypto wallets

The FBAR has the lowest threshold and the broadest definition of "financial account," so many crypto holders end up filing both FBAR and Form 8938.

Practical Tips from the Front Lines

  • Use a dedicated crypto tax software. Tools from CoinLedger and Koinly can auto‑import exchange balances and generate the daily‑high values you need for FBAR.
  • Document your valuation method. Keep a screenshot of the price source you used on the day of the high value; the IRS may ask for proof.
  • Don’t ignore small accounts. A $5,000 balance on three different exchanges adds up to $15,000 and triggers reporting.
  • Review annual statements. Some exchanges now provide a consolidated “Annual Tax Report” that includes the maximum balance figure.
  • Stay updated. BrightTax and Verni Tax Law regularly publish updates; the guidance could shift again in future years.

Frequently Asked Questions

Do I need to file an FBAR if I only hold crypto on a U.S. exchange?

No. FBAR applies only to accounts that are physically located outside the United States. Domestic exchanges are covered by regular tax reporting, not FBAR.

Can I use an ITIN instead of a Social Security Number?

Yes. The IRS allows filing FBARs with an ITIN, which is helpful for non‑resident aliens who do not have an SSN.

What if I missed a filing for a previous year?

File the late FBAR as soon as possible. If you’re not under investigation, the IRS may waive or reduce penalties, especially if you demonstrate good faith.

How do I convert volatile crypto values to USD for the maximum‑value test?

Pick a reputable price source (e.g., CoinMarketCap) and use the daily high price for each asset. Apply that price uniformly across all accounts for that day.

Are there any exceptions or higher thresholds for crypto?

No. The $10,000 threshold applies equally to crypto accounts. Unlike FATCA, there’s no higher exemption for digital assets.

Staying compliant isn’t optional-it’s the only way to avoid steep penalties and keep your crypto ventures thriving. Use the steps above, keep solid records, and file on time. When in doubt, bring a tax professional into the loop before the October deadline.

9 Comments

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    Anna Mitchell

    October 26, 2025 AT 00:12

    Just filed my FBAR for the first time this year using Koinly-saved me so much stress. I had no idea my tiny Binance balance + KuCoin stash added up to over $12k because of that one Bitcoin spike. Glad I didn’t wait until October.
    Pro tip: screenshot your daily highs. IRS doesn’t ask, but you’ll thank yourself later.
    Stay calm, stay compliant.
    ❤️

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    Pranav Shimpi

    October 26, 2025 AT 15:57

    bro u guys r overcomplicating this. u dont need koinly or coinledger. just go to binance, click on ur portfolio, copy the max value in usd, paste it in form. done. why pay for software when u can do it in 5 min? also, if u dont have acc number, just write ‘crypto wallet’ or ‘no acc num’-they dont care. i did it last year and got no issues. stop overthinking.
    also, dont use coinmarketcap, use binance price. its more accurate. i learned this the hard way.

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    jummy santh

    October 27, 2025 AT 09:56

    As a Nigerian living in Lagos with crypto holdings on Binance and KuCoin, I want to say: this is not just an IRS issue-it’s a global reality. Many Africans use these platforms because local banking is unreliable. But compliance is not betrayal; it’s responsibility.
    My advice: use your exchange’s official tax report, even if it’s in PDF. Print it. Keep it with your passport and visa documents. The IRS respects documentation, not excuses.
    Also, ITIN is your friend. You do not need an SSN to file. I filed mine with my ITIN last year-smooth as butter.
    Stay wise. Stay legal. Your future self will bow to you.

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    Kirsten McCallum

    October 28, 2025 AT 01:12

    You’re all missing the point. The real issue isn’t filing-it’s that the government now owns your digital life. If they can track your crypto balance on a foreign exchange, what’s next? Your smart fridge? Your Fitbit? This is the slippery slope. Compliance isn’t safety-it’s surrender.
    And don’t get me started on ‘voluntary disclosure.’ That’s just the IRS saying, ‘We know you’re guilty. Pay up.’

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    Henry Gómez Lascarro

    October 28, 2025 AT 11:01

    Let me just say this: anyone who thinks they can just ‘use CoinGecko’ and call it a day is either delusional or has never been audited. The IRS doesn’t care what you think is ‘reliable’-they care about consistency, traceability, and paper trails. If you switch from CoinMarketCap to Binance’s price feed mid-year, you’re inviting trouble. I’ve seen it happen. One guy got hit with $40k in penalties because he used different sources for different coins. Also, you don’t get to pick ‘the highest price’-you have to capture the actual daily high, not just the closing. And if you think you can file under ITIN without documentation proving residency? Please. The IRS has a whole team dedicated to catching people like you. Stop being lazy. Get a CPA. Pay the $300. It’s cheaper than jail time. And don’t even get me started on people who say ‘I only had $8k on one exchange.’ Bro, you had three. Add them. It’s math. Not magic.

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    Will Barnwell

    October 28, 2025 AT 21:49

    Why are we even talking about this? The FBAR rules for crypto are a joke. No one’s actually checking. I’ve had $25k on Binance for years and never filed. Still got my refund. The IRS has better things to do than chase crypto bros. If they wanted to catch everyone, they’d have to hire 10,000 more auditors. They’re not gonna do it. Just keep your head down.
    Also, who even uses BSA E-Filing? I just emailed my accountant a screenshot and said ‘do it.’ He did. No one asked questions.

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    Lawrence rajini

    October 28, 2025 AT 22:24

    Just filed my FBAR last week and it felt like leveling up in a tax RPG 🎮💸
    Used CoinLedger, automated the daily highs, boom-done in 20 mins.
    And yes, ITIN works. No SSN? No problem.
    Don’t stress. Just do it. Your future self will high-five you 🙌
    Also, if you’re reading this and haven’t filed yet-go do it now. Seriously. I’m not joking. The clock’s ticking. 🕒🔥

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    Matt Zara

    October 29, 2025 AT 21:02

    Hey everyone, I just want to say-this stuff is scary, but you’re not alone. I was terrified to file last year. Thought I’d get fined into oblivion. But I reached out to a local CPA who specializes in crypto, and they walked me through it step by step.
    Turns out, the IRS isn’t out to get you-they just want you to play fair. If you’re honest and show up, they’ll meet you halfway.
    And if you’re using a non-US exchange, you’re not shady. You’re just using tech that’s better than your bank. That’s not a crime.
    Be kind to yourself. Do the work. You’ve got this.

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    Jean Manel

    October 30, 2025 AT 17:38

    Of course you’re all panicking. You didn’t do your homework. You thought crypto was ‘unregulated’ so you didn’t track it. Now you’re scrambling because you know you’re guilty.
    And let’s be real-most of you are just trying to avoid penalties, not actually comply. You’ll file one FBAR and go right back to holding $50k on Binance without a care.
    Wake up. The IRS has blockchain analytics. They can trace your wallet to your IP. You’re not hiding anything. You’re just delaying the inevitable.
    And if you think your ‘ITIN loophole’ saves you? You’re delusional. They’ve been auditing those since 2022.
    Stop pretending this is a game. It’s not.

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