A single platform login is not a single FBAR account. A general investment account, a stocks and shares ISA and a SIPP reached through one password are normally three entries on FinCEN Form 114, each with its own account number and its own maximum value. The portfolio total on your dashboard goes nowhere on the report, and the shares and funds inside each wrapper are not listed.
This post is for US citizens and green card holders in Britain with a UK brokerage or share-dealing account, usually alongside other wrappers at the same provider, who prepare or check their own figures. It extends our guide to FBAR and FATCA for UK residents on one practical question: how to turn a consolidated platform view into correct lines on the report. It covers counting the accounts, what a nominee changes, reading the statements, transfers between wrappers, and accounts your login shows that are not yours.
How many FBAR accounts is one platform login
Count the account numbers, not the logins. FinCEN's line instructions ask for the number the institution uses to designate each account, and they require each account to be valued separately. A login is only a way in. Three wrappers carrying three designations are three entries, even when one firm runs them all.
Neither FinCEN nor the IRS has published anything on UK wrappers by name, so this is our reading of general rules and not a quoted ruling. The IRS manual on the FBAR (opens the official IRS page in a new tab) lists securities accounts among reportable financial accounts, and each wrapper normally has its own terms and its own reference. Statements are the best evidence. Look for the reference printed on each wrapper's statement, which often differs from the client number you use to sign in.
If a platform seems to use one reference for everything, ask it in writing how it designates each wrapper and whether it can produce a separate valuation for each. The report does have an amount unknown box, for an account whose value cannot be determined. It is a poor answer where the platform can run the valuation on request.
- Wrapper with its own account number: its own line and its own maximum value
- Client number used only to sign in: not an account, so never entered as one
- Cash inside a wrapper: part of that wrapper's value, with no separate line
- Separate cash account with its own number: its own line, valued on its own
- Shares and funds inside a wrapper: covered by the wrapper's single entry
- Wrapper closed during the year: still listed, at its highest value while open
Does a nominee holding change who reports the account
No. Having your shares registered to the platform's nominee company does not take them off the FBAR. The reportable item is the account the platform keeps for you, and its value includes what the nominee holds on your behalf. You do not add a line for the nominee or for each holding.
FinCEN's definition reaches the account from either direction. A US person has a financial interest as owner of record, and also where the owner of record is an agent, nominee or other person acting on their behalf. So the answer does not turn on whose name a share register shows. On the FBAR page at FinCEN (opens the official FinCEN page in a new tab) you will find the instructions, which ask for the full name of the institution holding the account. We use the firm that maintains the account and issues the statements, by its legal name and not its app brand.
The contrast is a share held directly. The IRS comparison of Form 8938 and FBAR requirements (opens the official IRS page in a new tab) treats foreign stock held outside a financial account as a Form 8938 item and not an FBAR item, so paper certificates stay off the FBAR. Move those shares onto a platform and they become part of a reportable account's value from that date.
US-listed shares do not change the analysis. The manual looks at where the account is located, so a UK platform account holding American shares is still a foreign account. Its exception for omnibus accounts concerns a US institution acting as global custodian, where the customer cannot directly access the foreign custodial account.
How do you find each wrapper's maximum value from platform statements
Take each wrapper's own statements for the calendar year, find the highest total of holdings plus cash, and note its date. Do this separately for every wrapper. Then convert each sterling figure at the Treasury rate for the last day of the calendar year, and round it up to the next dollar.
FinCEN's note on reporting maximum account value (opens the official FinCEN page in a new tab) calls for a reasonable approximation of the greatest value in the account, and allows reliance on periodic statements that fairly reflect it. A consolidated pack may show each wrapper at one date only, and annual tax packs are generally built around the UK tax year. The report runs from January to December, so two UK tax years are involved.
Statements stop being enough when you know of something between them: a large payment in, a sale awaiting reinvestment or a sharp market move in a concentrated holding. A portal valuation history then gives a better figure. A SIPP may send only an annual statement. The manual says that where periodic statements are not issued, the maximum is the largest amount in the account at any time, so use the provider's valuation history if there is one. Our post on the FBAR maximum value and exchange rate covers the conversion arithmetic.
- Download statements wrapper by wrapper, covering January to December
- Record each statement's closing total of holdings plus cash
- Mark each wrapper's highest figure and its date
- Check for known events between statements, and use a valuation history if there were any
- Convert at the Treasury year-end rate (opens the official US Treasury page in a new tab), round up, and keep one row per wrapper
How does a transfer between wrappers on the same platform affect the report
Each wrapper keeps its own maximum, so shares sold in the general account and bought again inside the ISA can sit within both lines for that year. Nothing is netted. A move between wrappers does not merge them, even though the platform's overall total runs on as if nothing happened.
The threshold is a separate step, and the published material pulls in two directions. FinCEN's instructions require a report where the aggregate of the maximum account values exceeds $10,000. The IRS manual (opens the official IRS page in a new tab), written for examiners, says money moved from one foreign account to another during the year must only be counted once. We run the test as the instructions describe, adding the maximum values, as our guide does. Where the result turns on one transfer and the total is close to the line, take advice on the facts.
The move also has a tax side that the FBAR does not show. Often called bed and ISA, it is a sale in one account and a purchase in another. The US does not recognise the ISA wrapper (opens the official GOV.UK page in a new tab), so a gain or loss on the sale goes on the US return through Form 8949 (opens the official IRS page in a new tab) in the usual way, and income in the ISA stays taxable. If the purchase is a fund, it may also bring a Form 8621 question, which our PFIC reporting service deals with. A transfer to a different provider is covered in our post on ISAs on the FBAR and Form 8938.
What does a report look like for three wrappers on one login
Take a US citizen employed as a pharmacist in Sheffield. One login gives her a general account holding 1,200 shares in a UK listed company, a stocks and shares ISA and a SIPP. She also has a current account at a bank. That makes four rows on her schedule and, if she files, four entries.
On 8 April she sells 600 shares in the general account and buys 600 of the same shares inside the ISA. The general account's highest statement total is 31 March, but a cash payment arrived on 2 April, so she knows that statement understates the peak and takes the portal valuation for 7 April. The ISA peaks on its 30 September statement. The SIPP peaks on 12 November in the provider's valuation history, after a contribution. The dashboard total peaks on 31 December, a date on which no wrapper was at its own highest.
She converts each sterling figure at the one year-end rate, rounds up and adds the four. If the total exceeds $10,000, she files one report listing all four by 15 April, extended automatically to 15 October. The 600 shares sit within both the general account's figure and the ISA's, and the dashboard total appears nowhere. The SIPP is on the list because, as our post on whether a UK pension is reportable explains, the FBAR exception for retirement plans covers US plans only. Its US tax position is a separate matter for our US and UK pensions service.
The sale goes on her Form 1040. Individual company shares are usually not PFICs, though a foreign company that is mostly passive can be one, so the holding still deserves a look. The same four rows feed Form 8938 if her specified foreign financial assets pass $200,000 at year end or $300,000 at any time, which uses the same year-end rate but has its own year-end test.
Which accounts on your login are not yours to report
A login can display accounts you do not own. Your report follows financial interest or signature authority, not what appears on the screen. A wrapper in your British spouse's sole name, visible on a shared household view, is not on your report unless you can instruct the platform to move what is in it.
FinCEN frames signature authority as the power to control the disposition of assets by direct communication with the institution. A read-only view gives you no such power. A dealing or withdrawal permission may well do so, and being able to act counts even if you never have. The IRS guidance on the FBAR (opens the official IRS page in a new tab) is the place to start, and our post on joint accounts with a non-US spouse covers the account you share.
Once the schedule is built, keep it with the statements behind it for the five years the records rule requires. The document checklist in our client portal lists what we ask for, and we prepare the schedule through our foreign income and FBAR reporting service alongside individual tax return preparation. For the wider rules, return to the guide to FBAR and FATCA for UK residents.
- Joint general account: your report, at full value, in the joint accounts part
- Spouse's sole wrapper you can only view: not on your report
- Spouse's sole wrapper you can instruct: check for signature authority before leaving it off
- US child's Junior ISA you operate: the child's report, and possibly yours as well
- Parent's wrapper under a power of attorney: signature authority once you can operate it
General information, not advice. The right answer depends on your circumstances and the tax year concerned.
