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FBAR & FATCA: what U.S.-based NRIs must report every year

Indian bank accounts, mutual funds, and insurance policies may need reporting even if they earn nothing — and the catch-up route matters.

CA Shyam S R02 May 20261 min read

If you're an Indian-origin taxpayer in the U.S. — citizen, green-card holder, or resident alien — your Indian bank accounts, mutual funds, and insurance policies may need to be reported every year, even if they earn nothing.

FBAR (FinCEN 114)

Required when the combined maximum balance of all foreign accounts exceeds USD 10,000 at any point in the year. It is filed with FinCEN, separately from your tax return, and covers accounts you own or merely hold signature authority over.

FATCA (Form 8938)

Filed with your 1040 when specified foreign financial assets cross thresholds that vary by filing status and residence — starting at USD 50,000 for single filers living in the U.S. Indian mutual funds and ULIPs commonly fall in scope, and PFIC rules can make mutual-fund gains punishing.

If you've missed years

Penalties for wilful non-filing are severe, but the Streamlined Offshore Procedures exist precisely for non-wilful catch-up. The right move is a structured disclosure — not quietly starting to file from this year.

Both sides: Your Indian ITR and U.S. return should tell one consistent story — coordinated preparation is the cheapest insurance there is.
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CA Shyam S R

Founder & Principal

Chartered Accountant (FRN 028561S). 15+ years advising businesses across India, the U.S., and Canada on audit, tax, and cross-border compliance.

This article is general information for a standard financial year and is not professional advice. Positions may change with amendments and circulars — please verify before acting, or speak with us. Speak with us.