FBAR vs Form 5472: Two Filings People Mix Up
TL;DR
FBAR = a U.S. person reporting foreign bank accounts. Form 5472 = a U.S. company reporting its foreign owner. They run in opposite directions, go to different agencies (FinCEN vs IRS), and apply to different people. A typical non-resident LLC owner files 5472, not FBAR; a typical U.S. expat files FBAR, not 5472.
The clean split
| FBAR (FinCEN 114) | Form 5472 | |
|---|---|---|
| Who files | A U.S. person (citizen / resident / green card) | A U.S. entity ≥25% foreign-owned |
| Reporting what | Foreign financial accounts over $10,000 aggregate | Transactions with the foreign owner / related parties |
| Filed with | FinCEN, via BSA E-Filing (not the IRS) | IRS, by mail/fax with a pro forma 1120 |
| Deadline | April 15, auto-extended to October 15 | April 15, extendable via Form 7004 |
| Typical filer | U.S. expat with overseas bank accounts | Non-resident e-commerce seller’s U.S. LLC |
The memory hook: FBAR looks outward from America; 5472 looks inward at America.
Which one is yours?
- Non-resident owner of a U.S. LLC (the typical cross-border seller): Form 5472, annually. No FBAR — you aren’t a U.S. person.
- U.S. citizen or green-card holder living abroad with foreign accounts over $10,000: FBAR. No 5472 — unless you also sit inside a foreign-owned entity structure.
- Mixed situations exist — a green-card holder who owns companies across borders can genuinely owe both. If your facts are layered, get the structure mapped once instead of guessing form by form.
What this comparison is NOT
- Neither is an income tax return. Both are information reports; income tax (1040 or 1040-NR) is a separate question.
- The FBAR threshold is aggregate. Three accounts of $4,000 each cross the $10,000 line together — it is not per-account.
- Neither is optional when triggered. Both carry serious penalties for non-filing; the 5472 exposure starts at $25,000, and FBAR penalties are their own well-known hazard.
This article is general information, not tax or legal advice. Confirm the rules that apply to your specific situation before acting.
File it the right way
Laramie Ledger Tax handles foreign-owned LLC filings at flat published prices, prepared and signed by a licensed U.S. tax preparer.
Get a filing quoteFrequently Asked Questions
What is the difference between the FBAR and Form 5472?
The FBAR (FinCEN 114) is filed by U.S. persons whose foreign financial accounts exceeded $10,000 in aggregate. Form 5472 is filed by U.S. entities that are 25%+ foreign-owned. They point in opposite directions.
I'm a non-resident with a U.S. LLC — do I file an FBAR?
Generally no. The FBAR applies to U.S. persons (citizens, residents, green-card holders). A non-resident owner of a U.S. LLC typically files Form 5472, not an FBAR.
Where is each one filed?
The FBAR goes through FinCEN's BSA E-Filing system, separate from the IRS. Form 5472 goes to the IRS by mail or fax attached to a pro forma 1120.
Can one person owe both?
Yes in mixed situations — for example a green-card holder (a U.S. person) who also owns a foreign-owned structure. Most people owe only one.