Americans investing in Portugal applying for golden visa must comply with FATCA and FBAR requirements in the United States. Reporting is mandatory.
FATCA
The Foreign Account Tax Compliance Act (FATCA), which was passed as part of the HIRE Act, generally requires that foreign financial Institutions and certain other non-financial foreign entities report on the foreign assets held by their U.S. account holders or be subject to withholding on withholdable payments. IRS Form 8938)
Reportable assets include:
- Foreign business ownership
- Foreign mutual funds or ETFs
- Non-U.S. brokerage and retirement accounts
Under FATCA, certain U.S. taxpayers holding financial assets outside the United States (above $50k) must report those assets to the IRS on Form 8938, Statement of Specified Foreign Financial Assets. There are serious penalties for not reporting these financial assets (as described below). This FATCA requirement is in addition to the long-standing requirement to report foreign financial accounts on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)
Americans applying for Golden visa program must open a bank account with FATCA compliant banks in Portugal. IRS publishes FATCA Foreign Financial Institution (FFI) List first day of each month. It includes all foreign financial institutions and branches with approved FATCA registration at the time the list is compiled. Financial Institutions in approved status as of February 23, 2026
FBAR
US citizens or residents obtaining a Portugal Golden Visa must file an FBAR (FinCEN Form 114) if the aggregate value of their Portuguese bank accounts and investment funds exceeds ($10,000) at any time during the calendar year. Reportable bank accounts are
- Bank accounts (checking and savings) held in Portuguese or other non-U.S. banks
- Pension accounts
- Foreign investment and brokerage accounts
