The short answer on the credit card FBAR question is that FinCEN has never said. The definition of a financial account, the form instructions and the IRS manual for FBAR examiners do not mention credit cards as an account type at all. What they do say about value settles most cases: a card you owe money on has a negative value, and a negative value is entered as zero.
This post is for US citizens and green card holders in Britain with a wallet of UK plastic: a bank credit card, perhaps a charge card, a store card and a travel card. It goes deeper than our guide to FBAR and FATCA for UK residents on one question. It sets out what the official texts say and leave unsaid, how a refund that leaves a card in credit changes the picture, how Form 8938 differs, and a checklist to run each January.
Does FinCEN have a credit card FBAR rule
No. The regulation, the FinCEN filing instructions and the IRS manual define financial accounts by listing bank, securities and other accounts, and none of them names a credit card account, either to include it or to exclude it. Any answer is therefore a reading of the general definition rather than a published rule.
The FinCEN instructions on the report foreign bank and financial accounts (opens the official FinCEN page in a new tab) page describe a financial account as including, but not limited to, a securities, brokerage, savings, demand, checking, deposit, time deposit or other account maintained with a financial institution, or with a person performing the services of one. The regulation adds an account with a person in the business of accepting deposits as a financial agency. Every listed example is a place where money or investments are held for you.
The IRS manual on the FBAR (opens the official IRS page in a new tab) mentions credit cards only once, in its list of evidence for wilful cases. It points examiners to debit or credit card statements from an offshore bank that show the holder spending offshore funds on everyday living in a way that hides their source. That is about tracing a hidden account through the card that draws on it, and says nothing about whether a card is an account in its own right.
How do you value a card that is in debt
At zero. FinCEN's instructions say the maximum value is a reasonable approximation of the greatest value of currency or nonmonetary assets in the account during the year, and that a negative result is entered as zero. A card that was owed money every day of the year never held any currency of yours.
This is why the unanswered definition question rarely matters for an ordinary card. The FBAR is due when the aggregate maximum value of your foreign accounts exceeds $10,000, and a card at zero adds nothing to that total. FinCEN's note on reporting maximum account value (opens the official FinCEN page in a new tab) repeats the zero rule and says each account is valued separately, so a card balance owed is never netted against a savings account.
The credit limit is not a value either. It is the bank's promise to lend, not money held for you, and nothing in the instructions treats available credit as an asset in the account. The same applies to a balance transfer or a purchase on an interest-free offer: each makes the card more negative. Our post on FBAR maximum value and the exchange rate covers the conversion for accounts that do have value.
- Balance owed all year: value is zero, adds nothing to the aggregate
- Credit limit or available credit: not a value in the account
- Balance owed on a card is not netted against any other account
- Overdrawn current account: also entered at zero, but the account is still listed
What if a refund leaves your card in credit
Then the card held your money, and the cautious reading is to list it. A refund or an overpayment that tips the balance into credit means the bank is holding funds for you, which looks very like a deposit. FinCEN has not addressed the point, but the general definition reaches accounts with institutions that hold money for customers.
There is an official view on the UK side of FATCA. HMRC's International Exchange of Information Manual, at IEIM401540, says a depository account can include a credit balance on a credit card, for example after a purchase has been refunded, where the issuer is in a banking or similar business. That is HMRC's guidance to UK institutions on what they report under the US-UK agreement, set out in its note on FATCA reporting (opens the official HMRC page in a new tab), not a FinCEN ruling on the FBAR. It does show how both governments approach the same money.
HMRC also lets card issuers keep such balances out of their own reporting. An issuer that meets the qualified credit card issuer conditions is a non-reporting institution for FATCA and the Common Reporting Standard. Others can treat overpayment balances as excluded accounts if their policies stop customer deposits above a fixed ceiling or refund the excess promptly. Those rules decide what your bank reports. They do not decide what you report, and they are no reason to leave a card off.
Do UK credit cards go on Form 8938
Rarely in practice. The Instructions for Form 8938 (opens the official IRS page in a new tab) define a financial account as a depository or custodial account at a foreign financial institution. A card in debt is valued at zero, and the form is due only once assets exceed $200,000 at year end or $300,000 at any time for a single filer living abroad.
The definition point is closer to settled here than on the FBAR, because Form 8938 borrows the FATCA meaning of a depository account. HMRC's manual reads the matching definition in the US-UK agreement as capable of covering a card credit balance. A card that held a credit balance during the year is therefore treated in our practice as a depository account for Form 8938, valued at its highest credit balance.
The amounts involved are usually small, and they matter only for a household whose other UK accounts already sit close to the Form 8938 threshold. The IRS comparison of Form 8938 and FBAR requirements (opens the official IRS page in a new tab) shows both forms covering deposit accounts at foreign institutions, so the same schedule of cards serves both. Our Form 8938 page explains the form, and the FBAR page explains the report itself.
Where do debit, charge, store and prepaid cards fit
Each follows the account behind it. A debit card is a key to your current account, and the current account is plainly reportable. A charge card or store card works like a credit card, so the same zero-unless-in-credit analysis applies. A prepaid or travel card holds your money in advance, so it carries positive value whenever loaded.
For a debit card you report the current account once, with its highest balance, and the card does not appear as a separate line. For a charge card paid in full each month, the account is in debit or at nil almost all the time, but an overpayment or refund can put it in credit just as with a credit card. A store card is often issued by a finance company rather than the shop, and the name and address on the FBAR is that company's.
Prepaid cards and travel money cards are the ones most likely to carry value, because you load them before you spend. Many are issued by electronic money institutions rather than banks, and our post on Wise and Revolut on the FBAR explains why we list e-money accounts held with a non-US entity even though FinCEN has not named them. A card issued by a US bank and used in Britain is not a foreign account at all.
- Debit card: report the linked current account, not the card
- Credit, charge or store card in debt all year: zero value, nothing added
- Any of those cards in credit at any point: list it at the highest credit balance
- Prepaid or travel card with a UK issuer: list it, valued at its highest loaded balance
- Card from a US bank used abroad: not a foreign account
How a US citizen teacher in Leeds sorts her cards
Take a US citizen teaching in Leeds with a current account and debit card, a credit card from the same bank, a department store card and a prepaid travel card. Her savings and current account together already pass the aggregate threshold, so an FBAR is due and the only question is which lines to add.
She goes through twelve months of statements. The store card was owed money all year, so it adds nothing. The credit card was in debt except for three weeks in March, when a refund for a cancelled holiday left it in credit, so we list it at that highest credit balance. The travel card held currency before two trips, and we list it too. The report goes to FinCEN by 15 April, extended automatically to 15 October, separate from her return, as part of our foreign income and FBAR reporting work alongside her individual tax return.
Had she missed a card that was in credit in an earlier year, the fix would be an amended report for that year, and for several years of gaps our streamlined filing service is the usual route. Closed cards still count for the year they were open, as our post on closing a UK account during the year explains. For the other accounts on the report, return to the guide to FBAR and FATCA for UK residents.
- List every UK card and the institution that issues it, not the brand
- Match each debit card to its current account and report the account once
- Scan each credit, charge and store card statement for any credit balance
- Record the highest credit balance and its date for any card that went into credit
- List prepaid and travel cards at their highest loaded balance
- Keep the statements with your FBAR records in case the figures are queried
General information, not advice. The right answer depends on your circumstances and the tax year concerned.
