US taxes while living abroad
FBAR vs. Form 8938: which foreign-account reports apply to you?
Last reviewed .
They are separate, and you may need both. The FBAR is required when your foreign financial accounts together exceed $10,000 at any time in the calendar year, and it is filed with FinCEN, not with your return. Form 8938 is attached to your tax return, and for people living abroad its thresholds start at more than $200,000 at year end or $300,000 at any time. A licensed tax professional should apply these rules to your own facts.
Key facts
| Fact | What the source says | Source |
|---|---|---|
| FBAR threshold | Aggregate foreign account value over $10,000 at any time in the year | Official source |
| FBAR filing | Electronically through FinCEN's BSA E-Filing System, not with the return | Official source |
| FBAR due date | April 15, automatic extension to October 15 | Official source |
| Form 8938 filing | Attached to the annual return, due with it | Official source |
| Form 8938 and FBAR | Form 8938 does not replace the FBAR | Official source |
Is the $10,000 FBAR threshold per account?
No. The FBAR threshold is the aggregate value of your foreign financial accounts exceeding $10,000 at any time during the calendar year. Three accounts at $4,000 each can cross it. The FBAR also reaches accounts where you have only signature authority, with some exceptions, so financial interest and signature authority both need checking.
What are the Form 8938 thresholds if you live abroad?
The IRS comparison page lists higher thresholds for people who meet its living-abroad definition. Different, lower thresholds apply to people living in the United States.
| Filing situation | More than this on the last day of the year | Or more than this at any time |
|---|---|---|
| Unmarried or married filing separately | $200,000 | $300,000 |
| Married filing jointly | $400,000 | $600,000 |
Do the two forms cover the same assets?
No. The IRS comparison table shows several differences. A yes or no question about foreign bank accounts is not a full inventory.
| Asset | Form 8938 | FBAR |
|---|---|---|
| Foreign deposit and custodial accounts | Reported | Reported |
| Account with signature authority only | Not reported unless you have another interest | Reported, with some exceptions |
| Foreign stock or securities not held in an account | Reported | Not reported |
| Foreign partnership interests | Reported | Not reported |
| Foreign mutual funds | Reported | Reported |
| Foreign life insurance or annuity with cash value | Reported | Reported |
| Foreign real estate held directly | Not reported | Not reported |
| Foreign currency or precious metals held directly | Not reported | Not reported |
What about penalties?
Both reports carry penalties for failures. The IRS comparison page warns that its tables are current only through their publication date. Check the current penalty rules in the official instructions rather than an amount quoted in an older article.
Checklist before you start
- List every foreign account, including joint, business and retirement accounts.
- Note the highest balance of each account during the year.
- Mark accounts where you have only signature authority.
- List foreign shares, funds, insurance policies and entity interests held outside accounts.
- Record the year-end value of each foreign asset.
- Use the Treasury year-end rate, or the rate the instructions specify, for conversions.
Common questions
Do I file the FBAR with my tax return?
No. The FBAR is filed electronically through FinCEN's BSA E-Filing System, separately from your federal tax return.
If I file Form 8938, do I still need an FBAR?
Possibly. The IRS states that Form 8938 does not replace the FBAR, so you may need to file both.
Does my foreign house go on the FBAR or Form 8938?
Foreign real estate held directly is not reported on either form, according to the IRS comparison. Holding it through an entity can change that for Form 8938.
Are joint accounts with a non-American spouse counted?
An account where you have a financial interest or signature authority can count toward the FBAR. Ask a preparer how joint ownership applies to you.
Official sources
- Comparison of Form 8938 and FBAR requirements. IRS.
- Report of Foreign Bank and Financial Accounts (FBAR). IRS.
- FBAR line item filing instructions. FinCEN.
Sources checked . Official pages change. Use the source over this summary if they differ.
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General information from IRS and FinCEN publications, not tax advice. Rules depend on your facts and the tax year. Confirm with a licensed tax professional before you file. US Expat Desk is a private company. We are not affiliated with the US government, the State Department, or the FBI.