International Money Transfer Limits: FBAR, Form 8938, and Penalties

There are no international money transfer limits set by the IRS or any other U.S. agency. You can send or receive any amount. What the federal government imposes instead are reporting requirements that kick in at specific dollar thresholds, and the penalties for skipping those filings can far exceed any tax you might owe on the underlying money.

Which form you need depends on how the money moves and what it is. A bank wire is handled differently from cash in a suitcase, a gift from a relative overseas is handled differently from a balance sitting in a foreign account, and each has its own trigger amount and its own filing.

Wire Transfers Through a Bank

For an ordinary electronic transfer through a U.S. bank or money-transfer service, the institution does the reporting. Your bank must file a Currency Transaction Report on any transaction involving more than $10,000 in currency, and under the Travel Rule it must collect and transmit your identifying information on any cross-border wire of $3,000 or more.¹ That information includes your name, address, the amount, and the recipient’s bank details, and it travels with the payment through every institution in the chain.²

None of this means you owe tax on the transfer, and you don’t get a copy of what your bank files. The reporting exists so federal agencies can spot patterns tied to money laundering, terrorism financing, or tax evasion.

One thing to avoid: splitting a large transfer into smaller ones to keep each below a threshold. That’s a federal crime called structuring, even when the underlying money is entirely legitimate.

Carrying Cash In or Out of the Country

The rules change when you physically carry, mail, or ship money across the border. If the total exceeds $10,000 in currency or monetary instruments, you must file FinCEN Form 105 with U.S. Customs and Border Protection at the time you cross.³ The $10,000 is aggregate: everything carried by you and anyone traveling with you counts together.

Currency covers U.S. and foreign coins and paper money. Monetary instruments include traveler’s checks, money orders, and bearer negotiable instruments and securities.³ Filing is a disclosure, not a tax. You can legally carry any amount as long as you report it.

Skipping the form is where travelers lose money at airports. Customs can seize and forfeit the entire unreported amount, and willful violations can bring fines up to $500,000 and up to ten years in prison.³ People treat $10,000 as a limit. It isn’t. It’s a trigger.

Gifts and Inheritances From Someone Abroad

Money received as a gift or inheritance from a foreign source is not taxable income to you. It can, however, require a Form 3520 filing once the amounts get large enough, and the IRS treats missed 3520s harshly.

From a nonresident alien individual or a foreign estate, the threshold is more than $100,000 in a single tax year, combined across that person and their related parties. Once you cross it, you must also separately identify each individual gift greater than $5,000.⁴

From foreign corporations or partnerships, the threshold is much lower and adjusts each year for inflation. For the 2024 tax year, the combined total from all such entities must exceed $19,570 to trigger the filing.⁴ The IRS looks harder at entity gifts because they can disguise what is really compensation or other taxable income.

The penalty for a late or missing Form 3520 is 5% of the unreported amount per month, up to 25% of the gift’s value.⁵ On a $200,000 gift, that reaches $50,000 for a form that costs nothing to file on time. The IRS can also recharacterize the unreported amount as taxable income if you can’t demonstrate it was genuinely a gift.

Foreign Bank Accounts (FBAR)

If you have a financial interest in or signature authority over foreign financial accounts whose combined value exceeds $10,000 at any point during the calendar year, you must file an FBAR on FinCEN Form 114.⁶ The $10,000 is the peak aggregate across all your foreign accounts, not the balance in any single one. Two accounts holding $6,000 each at the same moment trip the requirement, and you report both.

The FBAR is filed electronically through FinCEN’s BSA E-Filing System, not with your tax return. It is due April 15 following the reported year, with an automatic extension to October 15 that requires no paperwork.⁶

Fintech and Multi-Currency Wallets

Balances held in services like Wise, Revolut, or similar platforms based outside the United States may count toward the $10,000 FBAR threshold. What matters is whether the money sits at a foreign financial institution. A Wise account holding British pounds keeps the money at a non-U.S. bank, which makes it a foreign financial account for FBAR purposes. PayPal balances held in foreign currencies through overseas subsidiaries can raise the same question. When it’s close, including the account is safer than leaving it off.

Joint Accounts

If you share a foreign account with someone else, each U.S.-person owner reports the full value on their own FBAR. You don’t split the balance. Spouses who are both U.S. persons and file jointly can submit a single FBAR by completing FinCEN Form 114a, which authorizes one spouse to sign electronically for both.⁷

Foreign Financial Assets (Form 8938)

A separate reporting requirement under the Foreign Account Tax Compliance Act covers a broader range of foreign assets, including bank accounts, interests in foreign entities, and foreign-issued securities not held in a financial account. This is Form 8938, filed with your Form 1040.⁸

The Form 8938 thresholds are much higher than the FBAR’s and depend on your filing status and whether you live in the United States or abroad:⁸

Single or married filing separately, living in the U.S.: total value exceeds $50,000 on the last day of the year or $75,000 at any time during the year.
Married filing jointly, living in the U.S.: total value exceeds $100,000 on the last day of the year or $150,000 at any time.
Single, living abroad: total value exceeds $200,000 on the last day of the year or $300,000 at any time.
Married filing jointly, living abroad: total value exceeds $400,000 on the last day of the year or $600,000 at any time.

Form 8938 does not replace the FBAR. If you meet both thresholds, you file both. The two go to different agencies, cover overlapping but different assets, and carry separate penalties.⁹

What Missed Filings Actually Cost

These penalties are based on account balances or gift values rather than on unpaid tax, so they routinely exceed anything the underlying money could have generated in tax.

For a non-willful FBAR violation, the statutory baseline is up to $10,000 per account per year, adjusted for inflation.⁶ For a willful violation, it jumps to the greater of $100,000 (also inflation-adjusted) or 50% of the account balance at the time of the violation.⁹ Assessed year by year, a multi-year lapse can produce penalties that exceed the accounts themselves.

Missing Form 8938 triggers a $10,000 penalty. If you still haven’t filed within 90 days after the IRS sends you notice, another $10,000 accrues for each 30-day period, up to $50,000 in additional penalties. Any tax underpayment tied to an undisclosed foreign asset is subject to a 40% accuracy-related penalty rather than the standard 20%.⁸

Fixing Missed Filings

If you’ve realized you should have been filing but weren’t, the IRS offers routes to catch up that can reduce or eliminate penalties.

The Delinquent FBAR Submission Procedures apply when you failed to file FBARs but properly reported all income from the accounts and paid the tax due. You submit the late FBARs through the BSA E-Filing System with a statement of why they’re late. The IRS will not impose penalties if you reported all foreign account income, paid the tax, aren’t under examination or criminal investigation, and haven’t already been contacted about the missing FBARs.¹⁰

The Streamlined Filing Compliance Procedures cover taxpayers who also have unreported income from foreign accounts. You file amended returns and delinquent information returns with reduced penalties, but only if your failure was non-willful, meaning it came from negligence, inadvertence, mistake, or a good-faith misunderstanding of the law. You can’t use the streamlined procedures once the IRS has started a civil examination or a criminal investigation.¹¹

Two versions exist. The streamlined foreign offshore procedures apply if you live outside the United States and waive penalties entirely if you qualify. The streamlined domestic offshore procedures apply if you live inside the country and carry a 5% miscellaneous offshore penalty on the highest aggregate balance of your foreign accounts during the compliance period.¹¹

Deadlines at a Glance

FinCEN Form 105 is filed at the time you cross the border with more than $10,000. There is no after-the-fact deadline.
The FBAR (FinCEN Form 114) is due April 15 following the calendar year reported, with an automatic extension to October 15 that needs no separate request.⁶
Form 3520 is due the 15th day of the fourth month after your tax year ends (April 15 for most individuals). A tax return extension pushes it to the 15th day of the tenth month.⁵
Form 8938 is filed with your Form 1040 and follows the same deadline and extension.⁸

For Form 3520, the 5% monthly penalty begins accruing the day after the deadline, and the IRS rarely abates without a documented reasonable-cause argument. File early rather than late.

1
Internal Revenue Service. Bank Secrecy Act
2
Federal Register. Threshold for the Requirement To Collect, Retain, and Transmit Information on Funds Transfers and Transmittals of Funds That Begin or End Outside the United States
3
Financial Crimes Enforcement Network. FinCEN Form 105 Report of International Transportation of Currency or Monetary Instruments
4
Internal Revenue Service. Gifts From Foreign Person
5
Internal Revenue Service. Instructions for Form 3520
6
Internal Revenue Service. Report of Foreign Bank and Financial Accounts (FBAR)
7
Financial Crimes Enforcement Network. Reporting Jointly Held Accounts
8
Internal Revenue Service. Summary of FATCA Reporting for U.S. Taxpayers
9
Internal Revenue Service. Comparison of Form 8938 and FBAR Requirements
10
Internal Revenue Service. Delinquent FBAR Submission Procedures
11
Internal Revenue Service. Streamlined Filing Compliance Procedures