An FBAR for minor children is required whenever a child who is a US person has foreign financial accounts totalling more than $10,000 at any time in the year. There is no age exemption. The child is the filer, and a parent or guardian completes and signs FinCEN Form 114 if the child is too young to do so. A UK Junior ISA, Child Trust Fund or children's savings account all count.
American parents in Britain and the UAE are usually careful about their own accounts. Their children's accounts are another matter. Grandparents open savings accounts, parents fund a Junior ISA, and nobody connects a toddler's nest egg with a US Treasury report. This guide explains when a child must file, who signs, how a parent's own FBAR is affected, and which other US rules follow from a child holding UK investments.
When an FBAR for minor children is required
The FBAR rules apply to every "United States person", a term that includes US citizens and residents of any age. The IRS confirms in its FBAR guidance that a child is responsible for filing their own FBAR. If the child cannot file because of age, the parent, guardian or other legally responsible person must file it for them.
Is my child a US person?
A child born in the US is a citizen. A child born abroad to a US citizen parent is often a citizen from birth too, provided the parent meets the physical presence requirements in US nationality law, whether or not a US passport has been issued. Therefore, a child born in London who has never visited the US can still be a US person with an FBAR obligation. If you are unsure, check citizenship first.
The $10,000 threshold applies to the child
The test is the aggregate maximum value of all the child's foreign accounts during the calendar year. If the total exceeds $10,000 at any point, every account is reported, including small ones. Our guide to the FBAR maximum account value explains how to find and convert each balance.
| Child's account | FBAR-reportable? | Other US issue |
|---|---|---|
| UK children's savings account | Yes | Interest is US-taxable income of the child |
| Junior Cash ISA | Yes | Tax-free in the UK, taxable in the US |
| Junior Stocks and Shares ISA holding funds | Yes | Funds are usually PFICs, Form 8621 |
| Child Trust Fund | Yes | Possible PFIC and trust questions |
| NS&I Premium Bonds in the child's name | Generally yes | Prizes are US-taxable |
| UAE savings account in the child's name | Yes | Interest is US-taxable |
Who signs an FBAR for minor children and how to file
The FBAR is filed electronically through the FinCEN BSA E-Filing System. The child is entered as the filer, using the child's name, date of birth and Social Security number. If the child cannot sign, the parent or guardian signs electronically and indicates their capacity, such as "parent filing for child", in the filer title field. One FBAR is filed per child. A child's accounts cannot be added to a parent's FBAR in place of the child's own.
The deadline
The FBAR is due on 15 April following the calendar year, with an automatic extension to 15 October. No request is needed. The child does not have to file a tax return for the FBAR to be due; the two obligations are independent.
The parent's own FBAR
A child's account can also appear on a parent's FBAR. If a parent has signature authority, meaning the power to control the account by communicating directly with the bank, the parent has a reportable interest too. Most UK children's accounts operated by a parent meet that test. Consequently, the same account can appear on two FBARs: the child's, as owner, and the parent's, as signatory. Our guide to FBAR signature authority and joint accounts covers the rules.
Other US rules that follow
The FBAR is only a report. The income in the account has its own consequences.
The child's tax return and the kiddie tax
A child must file a US return if their income exceeds the filing thresholds for dependants, which are low for unearned income. Above a further threshold, the child's unearned income is taxed at the parent's rate under the "kiddie tax" rules on Form 8615. Interest in a Junior ISA is free of UK tax, so there is no foreign tax credit to offset the US tax.
PFICs in a Junior Stocks and Shares ISA
UK funds held in a Junior Stocks and Shares ISA are usually passive foreign investment companies. Each fund may need Form 8621, and gains can be taxed punitively. For this reason, a Junior ISA invested in UK funds is rarely suitable for a child who is a US citizen. Our guide to ISA tax for US citizens explains the problem.
Form 8938
Form 8938 is attached to a tax return, so a child needs it only if they are required to file a return and their foreign assets exceed the relevant threshold. For most children, the FBAR is the main reporting obligation.
If FBARs have been missed
A missed FBAR for minor children is common and usually fixable. If all the income was reported, or the child had no filing requirement, the Delinquent FBAR Submission Procedures are often the right route. If income was omitted, the Streamlined Filing Compliance Procedures may be needed. Our guide to the delinquent FBAR submission procedures compares the two, and our IRS streamlined filing page covers the fuller process.
An illustrative case
Consider an illustrative family in Surrey: an American mother, a British father and a seven-year-old daughter who is a US citizen. The facts are illustrative. The daughter has a Junior Cash ISA of £9,500 and a savings account of £1,200 from her grandparents. Together they exceed $10,000, so she needs her own FBAR listing both accounts, signed by her mother as parent. Because her mother operates both accounts, they also go on the mother's FBAR. The interest is small, so no US tax return is needed for the child this year.
If your children hold accounts outside the US, book a consultation with our FBAR and FATCA team. We file an FBAR for minor children and for parents together, and review whether the accounts themselves suit a US child.
Frequently Asked Questions
Does a child need to file an FBAR?
Yes. A child who is a US citizen or resident must file an FBAR if their foreign financial accounts exceed $10,000 in total at any time during the calendar year. There is no age exemption, and a parent or guardian files it if the child cannot.
Who signs an FBAR for a minor child?
If the child cannot sign, a parent or guardian signs FinCEN Form 114 electronically for the child and states their capacity, such as parent or guardian filing for the child. The child remains the filer of record.
Is a Junior ISA reportable on the FBAR?
Yes. A UK Junior ISA is a foreign financial account. It is reported on the child's FBAR if the child's foreign accounts total more than $10,000 at any time in the year, and often on the FBAR of a parent with signature authority.
Can I put my child's account on my own FBAR instead?
No. The child's accounts must be reported on the child's own FBAR. A parent with signature authority over the account reports it on their own FBAR as well, so the same account can appear on both.
Does my child need a US tax return as well as an FBAR?
Not always. The FBAR is separate from the tax return. A child needs a US tax return only if their income exceeds the IRS filing thresholds for dependants, although an FBAR can be due even when no return is required.
What if my child was born in the UK and has no US passport?
A child born abroad to a US citizen parent is often a US citizen from birth if the parent meets the physical presence requirements, even without a passport. If the child is a citizen, the FBAR rules apply. Confirm citizenship status before deciding.
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