FBARs (TD F 90-22.1 Report of Foreign Bank and Financial Account) must be filed by U.S. Citizens and residents who have signatory authority over, or a financial interest in a foreign bank account, or other financial account located in a foreign country. This is a topic that I have previously blogged on. Perhaps less understood is that even those who are not citizens or green card holders may be required to file FBARs if they have offshore accounts. The instructions to the FBAR form make clear that persons who are in, and doing business in the United States must also file the FBAR if they have an offshore bank account.
The Internal Revenue Service (IRS) FAQ on FBARs, however, states that this does not include athletes and entertainers who occasionally come to the U.S. to perform.
Whether or not you are a U.S. Citizen or resident, if you have an offshore bank account and have not filed an FBAR, you may wish to consult with a tax attorney to understand whether or not you have a tax problem.