International Tax Journal Article: How Many FBARs Are Enough?
- October 13, 2025
- Publications
In his latest article for Wolters Kluwer International Tax Journal, Michael J. Miller writes that more than one U.S. person may be obligated to report the same foreign financial account:
“As many readers of this publication are no doubt aware, U.S. persons who have a financial interest in, or signature or other authority with respect to, one or more foreign financial accounts generally are required to disclose such foreign financial accounts on “FBARs,” i.e., foreign bank account reports. By definition, this means that more than one U.S. person may potentially be obligated to report the same foreign financial account, but, as explained below, it is much worse than that.”
This article is reprinted with the publisher’s permission from the International Tax Journal, a bi-monthly journal published by WOLTERS KLUWER. Copying or distribution without the publisher’s permission is prohibited. To subscribe to the International Tax Journal or other WOLTERS KLUWER Journals please call 800-449-8114 or visit www.cchcpelink.com.