FATCA for Greek-American property owners.

One of the most under-discussed corners of Greek-American property ownership is the US-side reporting that comes with it. US citizens and US tax residents are taxed on worldwide income regardless of where they live, and have multiple reporting obligations on foreign assets that don't apply to citizens of most other countries. This article is the 2026 practical picture for Greek-Americans who own (or are considering owning, or are about to inherit) Greek property.

None of this is legal or tax advice for your specific situation — US international tax is complex enough that even basic compliance benefits from a US-side CPA experienced in expatriate work. But the framework matters, and most Greek-Americans we work with are surprised by what their US obligations actually are.

The four reporting layers

For US persons owning Greek property, four reporting frameworks may apply:

• FBAR (FinCEN Form 114) — for foreign bank accounts above thresholds
• FATCA / Form 8938 — for specified foreign financial assets above thresholds
• Form 3520 / 3520-A — for foreign trusts and certain large foreign gifts and inheritances
• Form 1040 with foreign income reporting — for foreign rental income, foreign capital gains, foreign pension income

Different forms have different thresholds, different penalties, and different scopes. Real estate itself is generally not reportable under FATCA or FBAR — but the financial assets associated with owning it often are.

FBAR — the bank account form

FBAR (FinCEN Report 114) requires US persons with foreign financial accounts whose aggregate maximum value exceeded $10,000 at any point in the year to report all such accounts annually.

• What counts as a "financial account": bank accounts (checking, savings), securities accounts, brokerage accounts, mutual fund accounts, certain insurance and annuity policies with cash value
• What doesn't count: the property itself, your name on title at the Greek cadastre. A bare Greek property held in your individual name with no associated financial accounts triggers no FBAR
• Threshold: $10,000 USD aggregate at any time during the year. So if your Greek bank account peaked at $12,000 equivalent in July, FBAR is required for the year even if it ended the year at $3,000
• Deadline: April 15, with automatic extension to October 15 (no application needed)
• Penalty: Non-willful failure to file: up to $10,000 per violation. Willful failure: greater of $100,000 or 50% of account value. The penalty regime is one of the harshest in US tax law

For most Greek-American owners with a Greek bank account that holds enough to pay ENFIA and utilities ($3,000–$8,000 equivalent typically), they're right at or near the FBAR threshold — and very often crossing it without realising it.

Form 8938 (FATCA) — the broader asset form

FATCA / Form 8938 requires reporting of "specified foreign financial assets" with higher thresholds than FBAR but a similar scope plus some additional items:

• What it includes: foreign financial accounts (broader definition than FBAR), foreign stocks/securities not held in a financial account, foreign mutual funds, foreign partnership interests, certain other items
• What it generally doesn't include: direct ownership of foreign real estate held in your own name (no entity wrapper), foreign social security, foreign government pensions, physical assets
• Thresholds (single filers living in US): $50,000 at year end OR $75,000 at any time during the year
• Thresholds (single filers living abroad): $200,000 at year end OR $300,000 at any time
• Married filing jointly thresholds: roughly double the above
• Filed with your annual Form 1040
• Penalty: $10,000 for failure to file, additional $50,000 max for continued failure after IRS notice. Plus a 40% accuracy-related penalty on understatements due to undisclosed foreign assets

The most common Greek-American situation: own Greek property + Greek bank account. The property itself doesn't count for Form 8938. The bank account does. If it stays below $50,000, Form 8938 is typically not required — but FBAR likely still is (because of its lower $10,000 threshold).

Form 3520 — inheritance and large foreign gift reporting

This is the form Greek-American heirs most often need and most often miss.

• Required when: a US person receives an inheritance or gift from a non-US person (a non-resident alien individual or foreign estate) of more than $100,000 in aggregate value in a year
• For inheritances of Greek property: the value reported is the fair market value of what you received, in USD. A Greek apartment worth €350,000 at inheritance triggers Form 3520
• Filed with (or separately from) your annual Form 1040, typically by April 15
• Penalty for failure to file: 5% per month, up to 25% of the unreported amount. On a €350,000 inheritance unreported, the potential penalty stack is six figures

Important: Form 3520 is a reporting form, not a tax form. The inheritance itself isn't taxed at the US recipient level (it may be taxed at the donor/estate level — but for Greek-resident parents the donor side typically isn't US-taxed). The danger is the penalty for non-filing, not any underlying tax.

Greek-Americans who inherit property and weren't aware of Form 3520 are one of the most common situations we see produced by IRS streamlined-compliance procedures retroactively. Catch this early — file the form, no underlying tax owed.

Annual income tax (Form 1040) — Greek rental income

If you rent your Greek property — long-term or STR — the rental income is reportable on your US Form 1040, Schedule E. Important details:

• Reported in USD using applicable annual exchange rate (or transaction-specific rates depending on accounting method)
• Allowable deductions include the Greek-equivalent expenses (mortgage interest, property tax / ENFIA, depreciation, maintenance, management fees, insurance) using US tax-accounting rules, not Greek
• Greek income tax paid on the rental is generally creditable against US tax via Form 1116 (Foreign Tax Credit). Most Greek-Americans renting Greek property pay no incremental US tax because Greek tax already covers it — but the form must still be filed
• Greek property depreciation under US rules: residential rental property depreciated over 27.5 years (US convention). Greek depreciation rules are different and don't transfer

The cost of getting this right is a Greek-and-US-experienced CPA. Typical fee: $1,200–$3,000 per year for an expat filing with Greek rental property. Worth the cost vs the risk of getting it wrong.

US capital gains on Greek property sale

If you eventually sell the Greek property, the gain is reportable on US Form 1040 as a capital gain:

• Greek property held over 1 year qualifies for long-term capital gains treatment in the US (0%, 15% or 20% depending on income tier, plus 3.8% net investment income tax for higher earners)
• Basis for US purposes is generally the USD value at acquisition or inheritance, plus capital improvements over the holding period
• Greek capital gains tax is currently suspended through 2026 (see our separate Greek property cost piece), so the foreign-tax-credit offset typically doesn't apply. US tax falls in full
• Currency moves are bundled into the gain calculation — the dollar value at sale vs the dollar value at acquisition determines the US-taxable gain, which can be very different from the euro-denominated gain

For a Greek-American who inherits a Greek property and later sells it, the IRS basis is generally the fair market value at inheritance (stepped up). So if the property was worth $400,000 at inheritance and you sell it 3 years later for $480,000, US-taxable gain is roughly $80,000 (subject to depreciation recapture if you rented it).

The streamlined compliance procedures — if you've missed past filings

If you discover you've missed FBAR, Form 8938, or Form 3520 filings for past years, the IRS Streamlined Foreign Offshore Procedures provide a structured way to come into compliance without the catastrophic penalties of the regular compliance regime. Available to taxpayers whose failure was non-willful (the vast majority of innocent diaspora cases). Process involves:

• Filing 3 years of amended 1040 returns (if income reporting was incomplete)
• Filing 6 years of FBAR returns
• Paying any tax due plus interest, but generally no penalties for non-willful streamlined filers
• Submitting a written certification of non-willfulness

For Greek-Americans who realise they've been non-compliant for several years: don't delay. Streamlined compliance is materially better than waiting for the IRS to discover the gap. A US international tax CPA can typically run the full streamlined package for $4,000–$10,000 depending on complexity.

US estate-planning interactions with Greek property

For US citizens, the US estate-tax regime applies to worldwide assets. As of 2026 the unified exclusion is around $13.6M per individual, $27.2M per married couple. For most Greek-Americans owning Greek property, this is well above their total estate — US estate tax doesn't apply.

For Greek-American higher-net-worth families approaching the threshold, planning around the location of assets can matter. But for most diaspora property owners, the US estate-tax angle is theoretical. The active US-side issues are the income-tax reporting on rental income and the gain calculation on eventual sale.

For Greek-American heirs receiving inheritance, the dominant US issue is Form 3520 (reporting form, no underlying US tax for the heir when the donor was non-US-domiciled).

The Greek-side interactions

Greek banks have, since the FATCA implementation in Greece (2014), the obligation to report US-person account holders to the IRS via the Greek tax authority. Practical implications:

• Opening or maintaining a Greek bank account as a US person triggers W-9 paperwork at the bank
• The bank reports your account balance and interest to AADE, which transmits to the IRS
• The IRS sees your Greek bank account exists. There is no anonymity. Your FBAR/8938 must match
• Some smaller Greek banks have de-prioritised new US-person accounts because of the FATCA cost overhead. Larger banks (National Bank, Eurobank) continue serving US-person customers

If you're a Greek-American with a Greek bank account that has been reported to the IRS via the Greek-FATCA process, and your US filings don't show it, expect IRS contact. This is the most common trigger for retroactive streamlined-compliance work for Greek-Americans.

What this actually costs Greek-American property owners annually

For a typical Greek-American with an Athens apartment + small Greek bank account, no rental income:

• FBAR filing: included in CPA's annual fee, typically
• Form 8938: typically not required if Greek financial accounts are below $50K
• US CPA fee (with foreign-account reporting): $800–$1,500/year

For Greek-American with Greek rental income:

• Above + Schedule E, depreciation, foreign tax credit: $1,500–$3,500/year

For Greek-American inheriting Greek property:

• Form 3520 in year of receipt: $500–$1,500 above baseline annual filing

Manageable costs vs the alternative of penalties from non-compliance.

How home watch fits

We're not US tax advisors. What we do for our Greek-American members on the US-reporting front:

• Provide structured euro-denominated annual statements that translate easily into Schedule E foreign-rental income reporting
• Track and document all property-related expenses with proper VAT invoices — your US CPA can convert these to the Schedule E deduction categories
• Coordinate with the Greek accountant whose annual filings can be cross-referenced against your US return
• Refer to US CPAs we've worked with who handle Greek-American expat work competently

Companion reading: Law 5221/2025 inheritance, Greek inheritance tax brackets, Greek-American property management landing, FX risk for diaspora owners.