Joint Filers & Form 114a Mechanics: A Practical Guide for Authorizing FBAR E-Filing and Recordkeeping

2025-08-15 04:28:30

Learn how U.S. expats can use Form 114a to authorize joint FBAR filing and keep records correctly.

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Why Joint Filers Need to Understand Form 114a

For U.S. expats and residents with foreign accounts, filing the FBAR (Report of Foreign Bank and Financial Accounts) is part of staying compliant with U.S. law. But when spouses share overseas accounts, or when a tax preparer handles the filing, a common question arises: “Can one person submit the FBAR for both?”

Yes — but only with the right authorization. Form 114a, the Record of Authorization to Electronically File FBARs, is the official way to give permission for one spouse (or a preparer) to file on behalf of another. This form is never sent to the government; instead, it’s kept in your records in case the Treasury Department requests it later.

In this guide, you’ll learn:

• Who needs Form 114a
  
  

• How to complete it step by step
  
  

• How it works for spouses and preparers
  
  

• What records to keep and for how long
  
  

A Quick Recap: What the FBAR Is

The FBAR is filed through FinCEN Form 114, not with your tax return, and it’s required for U.S. persons who have foreign financial accounts with an aggregate balance over $10,000 at any point during the year.

“U.S. person” covers:

• U.S. citizens (including expats)
  
  

• Green card holders
  
  

• Residents under the substantial presence test
  
  

• U.S.-based businesses and partnerships
  
  

The FBAR deadline is April 15, with an automatic extension to October 15.

Who Uses Form 114a

Form 114a is required when:

• Spouses want one person to e-file the FBAR for both (instead of separate submissions)
  
  

• A third-party preparer files on your behalf
  
  

Without Form 114a, each filer must log in to the BSA E-Filing System and submit their own FBAR.

Step-by-Step: Completing Form 114a

Even though it’s simple, accuracy matters because the form proves you authorized someone else to submit your FBAR.

1. Download the form
   
   

• Available from the FinCEN BSA E-Filing site.
  
  

2. Provide the filer’s name
   
   

• This is the person who will e-file on your behalf — spouse or preparer.
  
  

3. List the account holder’s information
   
   

• Include legal name, address, and taxpayer identification number.
  
  

4. Sign and date
   
   

• Both the person granting authority and the filer must sign.
  
  

5. Retain the form
   
   

• Keep it in your personal records for at least five years from the FBAR due date.
  
  

Joint Spouse FBAR Filing Mechanics

Here’s how it works when spouses choose joint filing:

• Single FBAR submission: The authorized spouse logs in to the BSA E-Filing System, lists both names, and reports all foreign accounts for both spouses.
  
  

• Form 114a signed: The non-filing spouse signs the form, authorizing the other to submit.
  
  

• One deadline for both: Both are considered compliant if the authorized filer submits on time.
  
  

Example:
Maria and David, U.S. citizens living in Spain, share two bank accounts totaling $35,000. Maria handles their taxes and FBAR. She completes Form 114a with David, keeps it in their files, and e-files one FBAR listing both names.

Using Form 114a with a Tax Preparer

When a preparer files an FBAR:

• Each account holder signs their own Form 114a giving the preparer permission.
  
  

• The preparer keeps copies for their records, and you should keep yours too.
  
  

• Even if the preparer has access to your financial data, they can’t legally file without your signed authorization.
  
  

Records You Must Keep

The FBAR rules require keeping these for five years from the due date:

• Completed Form 114a (if applicable)
  
  

• Account statements
  
  

• Account numbers and names of financial institutions
  
  

• Maximum balances for each account during the year
  
  

Failing to produce records if requested can lead to penalties — even if you filed on time.

Common Mistakes with Form 114a and Joint Filing

• Not signing before filing: The authorization must be signed before the FBAR is submitted.
  
  

• Throwing away the form early: Keep it for the full five years.
  
  

• Forgetting to list all accounts: Joint filing still requires reporting every qualifying account, even if only one spouse is listed on it.
  
  

• Mixing FBAR with tax returns: Form 114a is not filed with the IRS — it’s for your records only.
  
  

Penalties for Non-Compliance

Even if your omission is unintentional, the non-willful penalty can be up to $10,000 per violation (per year). Willful violations can go as high as the greater of $100,000 or 50% of the account balance.

According to FinCEN’s 2023 data, over 1 million FBARs are filed annually, but compliance errors still lead to significant penalties.

Best Practices for Staying Compliant

“Think of Form 114a as your permission slip — without it, the e-filing authority isn’t valid,” says Sarah Thompson, EA, a U.S. expat tax specialist.

• Complete and sign Form 114a before the FBAR is filed.
  
  

• Keep organized digital and paper records.
  
  

• Review account balances mid-year to avoid surprises.
  
  

• If in doubt, work with a preparer who regularly handles expat FBAR filings.
  
  

Real-Life Example: Late Filing Avoided Penalties

A couple in Singapore realized they missed signing Form 114a for their joint FBAR. They quickly signed and dated the form before the October extension deadline, e-filed on time, and kept the form. When FinCEN later inquired, they provided the signed form — avoiding any penalty.

FAQ

1. Do we send Form 114a to FinCEN?
No, keep it in your records for five years.

2. Can we still file separately if we have joint accounts?
Yes, but each spouse must log in and file their own FBAR.

3. Can a preparer file without Form 114a?
No, authorization is required.

4. What if we signed the form after filing?
It must be signed before the FBAR is submitted to be valid.

5. Do closed accounts need to be reported?
Yes, if they existed and met the threshold during the year.

Final Takeaway

Form 114a keeps joint FBAR filings legal and straightforward. Whether you’re authorizing a spouse or a tax preparer, the key is to sign it before filing, keep it for five years, and ensure every qualifying account is reported. With the right process, joint filing can save time while keeping you fully compliant.

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Multimedia Suggestions:

• Chart showing Form 114a filing process for joint filers vs. separate filers
  
  

• Sample (redacted) Form 114a layout for reference
  
  

M.Daniyal