Reporting accounts and assets in Türkiye

This is the obligation most often overlooked by Turks considered tax residents in the United States. U.S. citizens and tax residents must report their bank and investment accounts in Türkiye every year once they exceed certain thresholds. There are two main reports: the FBAR filed with FinCEN and Form 8938 attached to the tax return. On this page, you will find who must report what, the FBAR step by step, Form 3520 for gifts and inheritances from Türkiye, penalties, and correction options for late filers.

• Who must file: U.S. citizens and tax residents, including green card holders. Corporations, LLCs, partnerships, trusts, and estates are also considered "U.S. persons."
• Requirement: If the total value of your foreign accounts exceeded $10,000 at any time during the year, including bank accounts in Türkiye, reporting is required.
  • This is an aggregate value. If the combined value of two accounts exceeded $10,000 at any point, you report both.
  • Reporting is required if you have a financial interest or signature authority over the account. For example, if you have signature authority over your mother’s or father’s account in Türkiye, that account is also covered.
• It does not matter whether the account generates income.
• Covered accounts: bank accounts, brokerage (investment) accounts, and mutual funds. An account at a foreign branch of a U.S. bank is also covered by the FBAR; an account at a U.S. branch of a foreign bank is not.
• Accounts not reported: accounts held in your individual retirement account (IRA) or retirement plan in which you participate, government-owned accounts, and a few special situations.
• Joint accounts with your spouse: If all your foreign accounts are jointly held with your spouse, you may sign Form 114a and have your spouse report them on your behalf as well. This exception is not affected by whether you file your tax return jointly or separately.
• Foreign real estate you own directly is not reported on the FBAR or Form 8938. Rental income is reported with your worldwide income if you are a resident.
• The report is filed through FinCEN’s BSA E-Filing system, not with the IRS.

1. Find the highest value of each account during the year. Use your periodic account statements.
2. Convert to dollars. Use the U.S. Treasury’s published exchange rate (Treasury Reporting Rates of Exchange) for December 31, the year-end date.
3. Enter the BSA E-Filing system. Individuals filing for themselves may file an FBAR without registering in the system.
4. Complete and submit the form. Keep the submission confirmation.
5. Keep records for 5 years. For each account: the name on the account, account number, bank name and address, account type, and highest value during the year. Statements or a copy of the filed FBAR may be used for this purpose.

What you need to know:

• The deadline is April 15; it is automatically extended to October 15 without filing an extension request. You do not need to request an extension.
• For 2025 accounts, the deadline was October 15, 2026.
• The FBAR is not filed with the tax return.
• If you want to file on paper, you must first obtain an electronic filing exemption from FinCEN’s Resource Center.
• To authorize someone else to file on your behalf, complete FinCEN Report 114a. This form is not submitted; you keep it. An attorney, CPA, or enrolled agent registers as an organization in the system and files it that way.
• For an FBAR filed after October 15, select the reason for the delay from the list. If no appropriate reason is available, select "other" and provide an explanation.

• Form 8938 is filed with the tax return and is subject to the return’s deadline, including extensions.
• Who must file: U.S. citizens, resident aliens, and certain nonresident aliens ("specified individuals").
• Thresholds for people living in the United States:
  • Single (or married filing separately): total value over $50,000 at year-end or over $75,000 at any time during the year
  • Married filing jointly: over $100,000 at year-end or over $150,000 at any time during the year
• Thresholds for people living outside the United States:
  • Single (or married filing separately): over $200,000 at year-end or over $300,000 during the year
  • Married filing jointly: over $400,000 at year-end or over $600,000 during the year
• Differences in coverage:
  • Accounts at foreign financial institutions and foreign mutual funds are covered by both reports.
  • Foreign stocks not held in an account, foreign partnership interests, and foreign hedge funds are reported on Form 8938 but not on the FBAR.
  • Accounts over which you have only signature authority and foreign branches of U.S. banks are reported on the FBAR but not on Form 8938.
• Turkish Social Security rights: Payments from, and rights to receive payments from, a foreign government social security or social insurance program are not reported on Form 8938. An interest in a foreign pension plan may be reportable.
• Exchange rate: Convert the values to dollars using the U.S. Treasury rate on the last day of the tax year.
• Penalty: failure to report may result in a penalty of up to $10,000, plus $10,000 for every 30 days after IRS notification, up to a total of $60,000. Criminal penalties may also apply.
• The FBAR and Form 8938 are separate obligations. If the requirements are met, both must be filed.

• Form 3520 (Part IV): Report gifts and inheritances received from a nonresident alien individual or a foreign estate if their total during the year exceeds $100,000.
  • Amounts from related persons are aggregated. For example, gifts from your mother and father are calculated together.
  • Once the total exceeds $100,000, each gift exceeding $5,000 is listed separately.
  • The threshold for a "gift" from a foreign corporation or partnership is $20,573 in 2026 ($20,116 in 2025).
  • Gifts and inheritances are excluded from your income; Form 3520 is an information report.
  • Deadline: the 15th day of the fourth month following the tax year, generally April 15. An extension of the tax return also applies to Form 3520, no later than October 15. If you obtained an extension, check box 1k on the form.
  • Address: Form 3520 is mailed separately from the tax return: Internal Revenue Service Center, P.O. Box 409101, Ogden, UT 84409.
  • Penalty: for a gift not reported on time or accurately, 5% of its value per month, up to 25% (if there is no reasonable cause).
• Other forms: Additional reports may be required for situations such as interests in Turkish companies (Form 5471), or interests in a passive foreign investment company or qualified electing fund (Form 8621). These matters are complex; consult a tax professional.
• Schedule B Part III: The tax return asks whether you have foreign accounts.
• For reporting by company owners, see 14.4.

• Filing the FBAR late or not filing it at all is a violation. Civil and criminal penalties may apply; the penalty is determined based on the circumstances.
• Penalty maximums are updated annually for inflation. For penalties assessed on or after January 17, 2025, the maximum for a non-willful violation is $16,536. The limit is much higher for willful violations.
• If the IRS has not contacted you and there is no examination or investigation concerning you, file the late FBARs as soon as possible. Explain the reason for the delay.
• Streamlined Filing Compliance Procedures:
  • For individuals living in the United States or abroad.
  • You must certify in writing that the failure was non-willful.
  • They cannot be used if the IRS has begun an examination of your returns or if there is a criminal investigation.
  • A valid SSN or ITIN is required.
• Delinquent international information return procedures: For people filing information forms such as Forms 3520 and 5471 late.
• If willful neglect may be involved: the IRS Criminal Investigation Voluntary Disclosure Practice may be relevant. In this situation, consult an attorney without fail.

• IRS FBAR help line — general questions about FBAR obligations and filing methods
  • From the United States: +1 866 270 0733
  • From outside the United States: +1 313 234 6146
  • Hours: weekdays, 08:00–16:30 (U.S. Eastern Time)
• FinCEN BSA E-Filing help desk — technical problems with the system; weekdays, 08:00–18:00 (U.S. Eastern Time). Contact information is available on FinCEN’s website.
• FinCEN Resource Center — questions about paper FBAR exemptions and regulations; leave a message and they will call you back.

• Not filing an FBAR because the account earns no interest.
• Not reporting because each account is individually below $10,000, even though the total exceeds the threshold.
• Forgetting signature authority over a parent’s account in Türkiye.
• Sending the FBAR to the IRS with the tax return.
• Assuming that filing Form 8938 eliminates the need to file an FBAR.
• Converting values using an exchange rate other than the year-end Treasury rate.
• Failing to report a large inheritance or gift from Türkiye on Form 3520.

• Are my demand deposit and foreign-currency accounts in Türkiye covered? Bank accounts outside the United States are covered by the FBAR. If the total value exceeded $10,000 at any time during the year, you report all of them.
• I have signature authority over my mother’s account; the money is not mine. Signature authority also creates an FBAR filing obligation.
• Do I have to report my home in Türkiye? Real estate you own directly is not reported on the FBAR or Form 8938. If you are a resident, rental income is reported on your tax return.
• Is my Turkish Social Security retirement right reported on Form 8938? No. Social security payments and rights from a foreign government are not reported on Form 8938.
• I am an F-1 student. Do I have to file an FBAR? The FBAR is for U.S. citizens and residents. Determine whether you are considered a tax resident according to 15.1.
• I have not filed an FBAR for years. What should I do? If the IRS has not contacted you, file the late FBARs as soon as possible. Consider the streamlined compliance procedure for non-willful failures. If willful neglect may be involved, consult an attorney.

• FinCEN BSA E-Filing system
• File an FBAR without registering
• FBAR line-by-line filing instructions (PDF)
• FinCEN Report 114a: authorization to file on behalf of another person (PDF)
• Publication 5569: FBAR filing guide (PDF)
• Form 8938 (PDF) · Form 8938 instructions (PDF)
• Form 3520 (PDF) · Form 3520 instructions (PDF)
• Form 8621 (PDF)
• Form 5471 (PDF)
• U.S. Treasury exchange rates
• IRS – Streamlined compliance procedure