International Structures

FBAR and Your Dutch Business Account: the $10,000 Line

Updated: 6 October 2026 Holdwise editorial team United States FBAR Banking

Many Americans abroad miss the report of foreign bank and financial accounts (FBAR). This report is separate from any tax owed. You only report which accounts you own or control outside the United States. The threshold is low, so almost every American with a Dutch business has to file it. At Holdwise, we keep this answer up to date and change it when the rules change.

The threshold, precisely

A US person files an FBAR when the aggregate value of their foreign accounts is above $10,000 at any moment during the calendar year. Three details of this rule are important. Aggregate means that you add up every account, so five accounts of $3,000 each are above the threshold. At any moment means that one day above the threshold is enough, even when the year ends at zero. US person means citizens, green card holders and US residents, wherever they live.

For an American who operates a Dutch company, the threshold is usually crossed as soon as the business bank account is set up. Together, a personal current account, a savings account and the company account are above $10,000 in most weeks.

The company account counts

Signature authority is enough. A director of a Dutch BV (besloten vennootschap, the Dutch private limited company) can often authorise payments from the company account. In that case, the director reports the account, regardless of ownership. An owner-director reports it on both grounds. In the report, you give the maximum balance during the year, the bank's name and address and the account number. If you own more than 50%, you also report the account on the basis of ownership alone.

You report the maximum balance. If the BV receives a large payment and pays it on in the same week, you still report that peak. Keep a spreadsheet of the month-end and peak balances. This saves you a lot of work each spring.

Which accounts belong in the report

Dutch current and savings accounts, personal and business
Accounts at electronic money institutions and payment providers that keep funds in your name
Investment and brokerage accounts based outside the United States
Accounts over which you have signature authority for an employer or a company
Certain insurance and annuity products with a cash value

Dutch pension arrangements and social insurance normally fall outside the ordinary account definition, and a company pension's treatment depends on its form. Ask a US preparer about this where a policy has an assignable cash value.

Deadline and penalties

The FBAR is filed electronically with the Financial Crimes Enforcement Network on FinCEN Form 114, separately from the income tax return. It is due 15 April, with an automatic extension to 15 October. Filing is free. The form is for information only.

The penalties are high. For a non-wilful failure, you pay a penalty per report. For a wilful failure, the penalty is much higher and based on the account balances, and criminal charges are possible. In 2023, the Supreme Court ruled that the non-wilful penalty applies once per report, whatever the number of accounts. This helps anyone with several accounts. If your omission was non-wilful, you can use correction procedures. Act before the authorities contact you, so you keep these options.

Each year, every Dutch BV files the same set of documents. These are the VAT returns, the corporate tax return, the annual accounts at the KVK and the UBO check. We do all of it for you. See corporate secretarial services in the Netherlands.

A Dutch BV files the corporate tax return by 1 June, the VAT return every quarter and the payroll tax return every month. The annual accounts are due within twelve months. See running a Dutch BV: taxes, filings and every deadline.

FBAR and Form 8938 are different reports

Both reports are about foreign assets and overlap a lot. Many owners therefore think one replaces the other. Each report has its own rules. The FBAR is for accounts, and the threshold is $10,000. You file it with FinCEN. Form 8938 is the statement of specified foreign financial assets under the Foreign Account Tax Compliance Act (FATCA). You file it with your income tax return, and it includes more assets, such as an interest in a foreign company. Its thresholds are higher and depend on your filing status and residence. Most Americans with a Dutch BV file both, based on the same data.

The complete annual set, including Form 5471 and the net CFC tested income calculation (NCTI, formerly GILTI), appears in the annual filing guide for US owners. The Dutch side of this, setting up the account itself, is a separate step: the guide for foreign-owned Dutch accounts covers what the bank asks for.

Free advice

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Part of Doing Business in the Netherlands, the complete 2026 guide.

Frequently asked questions

Do I report my Dutch BV account if the company owns the money? +

Yes, when you have signature authority over it. You report accounts you control as well as accounts you own. A director who can authorise payments therefore reports the account and states the maximum balance during the year.

What if I crossed $10,000 for one day? +

You file an FBAR for that year. One moment above the aggregate threshold is enough. You report the maximum balance, so you report that peak.

Does filing an FBAR mean paying US tax? +

The FBAR is for information only. Filing it costs zero tax. You settle the tax on the income in your income tax return, where foreign tax credits and treaty positions apply.

I have missed FBARs for previous years. What now? +

You can still correct this. If you have a reasonable explanation and zero unreported income, you can use the delinquent filing procedures. The streamlined procedures are for broader non-wilful cases. You use both through a US tax professional. File before the authorities contact you, so you keep the most options.

Does my Dutch bank report my account to the United States anyway? +

Yes. Under FATCA, Dutch banks share account information on US persons, so the US authorities receive data separately from your filing. Make sure that what you file matches what the bank reports.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 6 October 2026