Yes. Authority over a company’s foreign financial account may create a personal FBAR reporting obligation, even when you do not own the funds.
Officers and employees should review their bank-registered authority, particularly when handling treasury or accounting responsibilities.
1. What Authority Counts?
Signature or other authority generally means the ability to control the disposition of account assets through direct communication with the financial institution, either alone or jointly with another person.
Authority to instruct transfers or withdrawals may qualify. View-only access or internal approval authority does not necessarily qualify. Review the actual powers rather than the job title.
Reference: IRS — FBAR: Signature or Other Authority
2. What About Accounts in the United States?
Account location, rather than the bank’s nationality, determines whether it is foreign for FBAR purposes.
An account at a Japanese bank’s New York branch is generally not foreign; an account at a U.S. bank’s Tokyo branch generally is.
Reference: IRS — FBAR: Foreign Country
3. Are Personal and Company Accounts Considered Together?
A U.S. person generally reviews reportable foreign accounts held through financial interest or signature authority against the $10,000 aggregate threshold at any time during the calendar year.
Company-account authority can therefore create a filing requirement despite small personal balances, subject to applicable exceptions.
Reference: IRS — Report of Foreign Bank and Financial Accounts
4. Does the Company’s Filing Replace Mine?
Not automatically. Review the company’s and individual’s obligations separately.
Exceptions apply to certain officers and employees of qualifying institutions or listed companies. Special deadline relief also applies to some signature-authority filers. Neither applies universally.
An employer may file an employee’s FBAR with appropriate authorization. This is different from an exemption.
References: FinCEN — Reporting Corporate Accounts, IRS — FBAR Requirements and Relief
Information to Gather
- Your U.S. tax circumstances
- Account country, bank, and branch
- Account-owning entity and group relationships
- Bank-registered authority
- Dates authority began and ended
- Maximum annual account balances
- Prior company and individual FBAR filings
We review authority and available exceptions to identify necessary steps. Provide only an overview initially. Obtain internal approval before sharing company account records through the method we specify separately.
This answer provides general information. Requirements and relief depend on authority, employer characteristics, and the reporting year.
Information reviewed: October 14, 2026
