Mutual Funds & FBAR Reporting

Mutual Funds & FBAR Reporting

FBAR Mutual Fund Filing

FBAR and Mutual Fund Filing: When a U.S. Person has foreign mutual funds or other investment funds, the person has an FBAR reporting and IRS disclosure requirement. How to report the Foreign Mutual Funds and Investment Funds on the FBAR will vary based on how they are being held by the U.S. Person.

For example, if the funds are in a single “investment” account, it will be reported different than if they are behind held in individual accounts.

And, with the IRS taking an aggressive position on matters involving foreign account compliance, it is important to remain compliant.

We will summarize Mutual Fund and FBAR reporting requirements.

FBAR & Investment Accounts

When a U.S. person has a foreign investment account, the account is reportable — and the acronym FBAR can be deceiving. 


Because it is not just Foreign Bank Account Reporting, but rather Foreign Bank and Financial Account Reporting.

Therefore, taxpayers must report more than just a checking or savings bank account.

Rather, investment accounts are reportable as well. Moreover, the FBAR mutual fund requirement can be unnecessarily complex — especially when reconciling the FBAR and tax requirement reporting.

Investment Account Value for FBAR

Generally, the total highest or maximum value of the account is reported.

The filer will find the date that shows the highest annual aggregate total and report that total. Since the investments are in an account — they are not reported individually.

Mutual Funds & FBAR

If the mutual funds are in an investment account, then the investment account is reported.

But, if the taxpayer has individual Mutual Funds, then the individual funds are generally reported on the FBAR.

Unlike a stock certificate, which is not an account and not reportable on the FBAR, the mutual fund will usually have an account number and therefore should presumably be reported on the FBAR.

If the Mutual Funds are in an account, then the account number — not the individual funds — is reported for FBAR.

Depending on the value of the Mutual Funds and/or if there were any excess distributions will impact if the Form 8621 is also filed.

FBAR Lawyers For Mutual Funds and Investment Late Reporting

Our FBAR Lawyer team specializes exclusively in international tax, and specifically IRS offshore disclosure, including mutual fund FBAR disclosure.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our attorneys have worked with thousands of clients on offshore disclosure matters, including FATCA & FBAR.

Each case is led by a Board-Certified Tax Law Specialist with 20 years of experience, and the entire matter (tax and legal) is handled by our team, in-house.

*Please beware of copycat tax and law firms misleading the public about their credentials and experience.

Less than 1% of Tax Attorneys Nationwide Are Certified Specialists

Sean M. Golding is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.

Recent Case Highlights

  • We represented a client in an 8-figure disclosure that spanned 7 countries.
  • We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
  • We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
  • We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
  • We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.

How to Hire Experienced Offshore Counsel?

Generally, experienced attorneys in this field will have the following credentials/experience:

  • 20-years experience as a practicing attorney
  • Extensive litigation, high-stakes audit and trial experience
  • Board Certified Tax Law Specialist credential
  • Master’s of Tax Law (LL.M.)
  • Dually Licensed as an EA (Enrolled Agent) or CPA

Interested in Learning More about Golding & Golding?

No matter where in the world you reside, our international tax team can get you IRS offshore compliant. 

Golding & Golding specializes in FBAR and FATCA. Contact our firm today for assistance with getting compliant.

Schedule Your Confidential Reduced-Fee Initial Consultation with a Board-Certified Tax Attorney Specialist


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Sean M. Golding


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