FBAR (FinCEN 114) filing

Your U.S. LLC is a "United States person" for this report. The rule counts any company "created, organized, or formed under the laws of the United States" — so a Wyoming or Delaware LLC qualifies regardless of who owns it, and regardless of being disregarded for income tax and owing nothing. If the company held accounts outside the United States and their combined highest balances passed $10,000, the company files FinCEN Form 114.

Two questions decide it for the company. First: did the company hold any account outside the United States at any time during the year, including one it opened and closed? Second: add up the highest balance each of those accounts reached during the year — each account at its own peak, even when the peaks fell in different months. Is the total more than $10,000? Two yes answers mean the company files.

The second step is where owners get it wrong. The test is not "did we ever hold $10,000 at one moment". An account that peaked at $6,000 in March and a second that peaked at $6,000 in September add to $12,000 for this purpose, even though the money was never in both at the same time.

What counts as an account outside the U.S.: a bank account at any bank outside the United States; balances a payment app holds for you outside the U.S. (Wise, Revolut, Payoneer, Paysera, Airwallex, PayPal outside the U.S.); an investment or brokerage account; an account opened and closed within the same year.

What does not count: accounts held in the United States, including Mercury, Relay and ordinary U.S. banks; an account holding only cryptocurrency and no ordinary money; your own personal accounts, which are the separate question below.

How to tell where a Wise or Payoneer balance actually sits. Open the account details for each currency inside the app. An IBAN beginning BE is Belgium, GB the United Kingdom, LT Lithuania. A U.S. routing number means that balance is held in the United States. One app commonly holds some balances abroad and some in the U.S., so check each currency rather than judging the app as a whole.

Do you have to file personally? Only if you are a U.S. person yourself — a citizen, a green-card holder, or someone who spent enough days in the United States to be treated as a resident, counted over three years rather than one. Most non-resident owners are none of these and file nothing in their own name. If you are one, that is a second report, in your own name, covering your own accounts, and it is not part of the company fee.

The FBAR is an information report, not a tax: nothing is owed on it. It goes to FinCEN through the BSA E-Filing system, separately from any tax return, and the penalties for not filing are out of all proportion to the effort of filing.