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Last updated October 26, 2026.

Brazilian Accounts and the $10,000 FBAR Line: A 15-Minute Check (2026)

The Alt Desk · Brazil · Checked against official sources, October 2026 · Educational only, not financial advice

You opened a bank account in Brazil. Maybe you parked some reais in a CDB too. The US side has a yearly report for that. The line is lower than most people expect, and the way it adds up surprises a lot of people.

The rule in one paragraph

The IRS says a US person must file an FBAR, on FinCEN Form 114, if they have a financial interest in or signature authority over at least one financial account outside the US, and the total value of those accounts was more than $10,000 at any time during the calendar year.[1] A US person includes citizens and residents, and also entities like LLCs and trusts.[1] The IRS also says it doesn't matter whether the account earned any taxable income.[1]

Two words do the heavy lifting: "total" and "any time." The IRS gives a plain example. If two accounts have a combined balance over $10,000 at any one time, both accounts have to be reported.[2]

The 15-minute max balance check

Do this once for last year, and once for this year so far.

  1. List every account you hold at a bank or broker in Brazil. Checking, savings, a brokerage account, the account your CDB sits in. Add any account where you can sign, even if the money isn't yours.
  2. Find the highest balance of each one during the year, in reais. FinCEN's instructions say periodic statements can be used, as long as they fairly reflect the account's highest value.[3]
  3. Convert each one to dollars using the Treasury exchange rate for the last day of the calendar year.[3][4] FinCEN's instructions say to round up to the next whole dollar.[3]
  4. Add the dollar amounts together. If the total is over $10,000, the FBAR rule applies to that year.[3]

Why the total can surprise you

The instructions add up each account's own highest value for the year.[3] They don't ask whether those highs happened on the same day. So money you moved from one Brazilian account to another can show up in both numbers.

Made-up example. Account A is a checking account. Its highest balance was R$ 30,000, in March. In April you moved most of it into Account B, which holds a CDB. Account B peaked at R$ 28,000 in September. Say the year-end Treasury rate was 5.50 reais per dollar. That rate is made up for this example.

On these example numbers, neither account came close to $10,000 alone. You never had more than about R$ 30,000 in Brazil at once. The added-up maximums still cross the line.

What counts as an account

The IRS says an account at a financial institution outside the US is generally a foreign financial account.[1] That covers bank accounts, brokerage accounts and mutual funds.[1]

If you hold securities inside a foreign brokerage account, the account is what gets reported. You don't list each holding separately.[2] An account at a foreign branch of a US bank is still reported on the FBAR.[2]

When and where it's filed

The FBAR is due April 15 after the year it covers. The IRS says there's an automatic extension to October 15, and you don't need to ask for it.[1]

It isn't part of your tax return. It's filed electronically with FinCEN through the BSA E-Filing System.[1]

Form 8938 is a separate test

Form 8938 is a different form, attached to your tax return, with higher lines.[2] For an unmarried person living in the US, the IRS lists more than $50,000 on the last day of the year, or more than $75,000 at any time during the year.[2] For a married couple filing jointly in the US, it's $100,000 and $150,000.[2] The lines are higher again for people living outside the US.[2]

The IRS says filing Form 8938 does not replace the FBAR.[2] They are two checks with two sets of numbers.

The records the IRS wants you to keep

For each account on an FBAR, the IRS lists five things to keep: the name on the account, the account number, the bank's name and address, the type of account, and the highest value during the year.[1] It says to keep them for five years from the FBAR due date.[1] Statements count, if they show that information.[1]

If you missed a year

The IRS says filing late or not at all is a violation and may lead to penalties.[1] It also says that if the IRS hasn't contacted you about a late FBAR, and you're not under investigation, you should file the late FBARs as soon as possible to keep penalties to a minimum.[1]

Make next year a five-minute job

The hard part of this check is step two. Finding each account's highest balance means digging through a year of statements. Writing it down as you go turns it into a quick sum.

That's what the free Two-Country Money Tracker is built for. It logs both sides of every transfer the day it happens. It has a year-end step to write down the highest balance and the year-end balance of each Brazilian account. And it puts the official US and Brazil rules in one table, with a source for each.

Get the free Two-Country Money Tracker

Log every transfer and every account balance as you go, so the year-end check is a quick sum. Made-up example numbers only.

Get the free tracker
A deeper CPF and banking guide is coming.

Sources

  1. IRS, Report of Foreign Bank and Financial Accounts (FBAR): who must file, due dates, how to file, records and late filing: irs.gov
  2. IRS, Comparison of Form 8938 and FBAR requirements: irs.gov
  3. FinCEN, FBAR filing instructions, maximum account value and exchange rate steps: fincen.gov
  4. U.S. Treasury Fiscal Data, Treasury Reporting Rates of Exchange: fiscaldata.treasury.gov

This article is educational and informational only. It is not financial, tax, or legal advice, and it is not tailored to your situation. The author is not a licensed tax, legal, or financial professional. The reporting notes are general US notes only, based on IRS and FinCEN guidance. Not financial advice. Educational only. Rules and figures described are current as of October 2026 and can change.

Rules in Brazil and the US change. Check each rule against the official source linked above before you act.

TAD, The Alt Desk. Brazil. Tangibles. Rails.