FBAR vs. Form 8938: What Americans Abroad Need to File
Updated for 2026 | Atlantic Tax Advisory PLLC
FBAR and Form 8938 are frequently confused because both can involve foreign financial accounts. They are separate reporting regimes, use different definitions and thresholds, and in some cases the same account must be reported on both.
This article is part of Atlantic's international tax series. See the 2026 U.S. Expat Tax Guide for the broader framework.
FBAR: FinCEN Form 114
A U.S. person generally has an FBAR filing requirement when the aggregate value of foreign financial accounts in which the person has a financial interest or signature or other authority exceeds $10,000 at any time during the calendar year. The threshold is aggregate: multiple smaller accounts can trigger reporting.
The FBAR is filed electronically with FinCEN through the BSA E-Filing system. It is not attached to Form 1040.
Form 8938: Statement of Specified Foreign Financial Assets
Form 8938 is an IRS information return attached to the taxpayer's annual federal income tax return when the applicable requirements are met. It can cover foreign financial accounts as well as certain specified foreign financial assets that are not themselves financial accounts.
Form 8938 Thresholds for Individuals Living Abroad
For qualifying specified individuals living abroad, the current thresholds are substantially higher than the FBAR threshold. A taxpayer filing other than a joint return generally files when specified foreign financial assets exceed $200,000 on the last day of the tax year or $300,000 at any time during the year. For a married couple filing jointly, the thresholds are generally $400,000 on the last day of the year or $600,000 at any time during the year.
The Key Differences
FBAR uses a greater-than-$10,000 aggregate foreign-account threshold at any time during the calendar year.
Form 8938 thresholds vary by filing status and whether the taxpayer qualifies as living abroad.
FBAR can apply to signature authority even without beneficial ownership, subject to its rules and exceptions.
Form 8938 can include certain foreign stock, partnership interests, and other specified assets held outside a financial account.
FBAR is filed with FinCEN; Form 8938 is attached to the federal income tax return.
Filing one form does not automatically satisfy the other filing requirement.
Example: Several Foreign Accounts
Suppose an unmarried U.S. citizen living abroad has three foreign bank accounts with maximum balances of $4,000, $5,000, and $3,000 during the year. If the combined value exceeded $10,000 at the same time, an FBAR requirement can arise even though no individual account exceeded $10,000. The same facts alone may be far below the Form 8938 threshold for a qualifying taxpayer living abroad.
Common Mistakes
Looking only at each account separately instead of the FBAR aggregate threshold.
Assuming Form 8938 replaces FBAR.
Ignoring signature-authority accounts for FBAR analysis.
Assuming only bank accounts can be relevant to Form 8938.
Failing to keep records of maximum annual account values.
Treating foreign-account reporting as an income-only issue when an account may be reportable even if it produced little or no income.
Frequently Asked Questions
If I file Form 8938, do I still need an FBAR?
Possibly. The IRS specifically states that filing Form 8938 does not replace an otherwise applicable FBAR obligation.
Is the FBAR attached to my tax return?
No. It is filed electronically with FinCEN.
Does living abroad eliminate FBAR filing?
No. U.S. persons abroad can still be subject to FBAR reporting.
Primary Government Resources
How Atlantic Tax Advisory PLLC Can Help
Cross-border tax compliance is highly fact-specific. Atlantic Tax Advisory PLLC helps U.S. taxpayers abroad analyze filing obligations, international information reporting, foreign tax issues, and available compliance options before a position is taken on a return.
Important Disclaimer
This article is for general educational purposes only and is not tax, legal, accounting, or investment advice. International tax rules are fact-specific and can change. Consult a qualified tax professional regarding your particular circumstances.
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