FBAR vs Form 8938: Which Foreign Account Report Do You Need?

The FBAR and Form 8938 sound like the same thing, but they are separate reports with different rules, and many people with foreign accounts need to file both. They are related, they overlap, and they get mixed up constantly. Here is a clear, practical explanation of what each one is, who files it, how they differ, and how to figure out where you stand. No jargon and no alarm, just the facts you need to take the next step.

Quick answer

If you are short on time, here is the short version.

• The FBAR (FinCEN Form 114) reports your foreign financial accounts. It is filed with the Financial Crimes Enforcement Network, known as FinCEN, not with the IRS. It generally comes into play when your foreign accounts add up to more than 10,000 US dollars at any time during the year.
• Form 8938 reports a broader set of foreign financial assets. It is filed with the IRS as part of your tax return. The dollar levels that trigger it are higher than the FBAR level and depend on your filing status and whether you live in the US or abroad.
• Many people who have foreign accounts end up filing both, because the two forms have different rules and different purposes. Filing one does not cover the other.

What the FBAR is

FBAR stands for Report of Foreign Bank and Financial Accounts. The actual form is called FinCEN Form 114.

The key thing to understand about the FBAR is where it goes. It is not filed with the IRS and it is not part of your tax return. It is filed electronically with FinCEN, a bureau of the Treasury Department, through the BSA E-Filing System.

Who it applies to, in general terms: a US person who has a financial interest in, or signature authority over, one or more foreign financial accounts may need to file if the total value of those accounts adds up to more than 10,000 US dollars at any point during the calendar year. “US person” is broad. It includes citizens, resident aliens, and certain entities like trusts and estates.

Two details trip people up:

• The 10,000 US dollar figure is a combined total, not a per-account amount. If you have two accounts that together crossed 10,000 US dollars at any single moment during the year, both accounts are generally reportable, even if neither one alone was very large.
• “At any time during the year” means the highest balance counts. An account that briefly spiked and then dropped can still put you over the line.

The FBAR is generally due April 15, with an automatic extension to October 15 if you miss the April date. You can read the overview on the IRS FBAR page.

What Form 8938 is

Form 8938 is called the Statement of Specified Foreign Financial Assets. It comes from a law known as FATCA, and unlike the FBAR, it is filed with the IRS, attached to your annual income tax return.

Form 8938 covers a wider net than the FBAR. It reports specified foreign financial assets, which includes foreign financial accounts but also certain assets that are not accounts at all, such as foreign stock or securities held outside of an account, foreign partnership interests, and some foreign-issued financial instruments.

The dollar levels that trigger Form 8938 are higher than the FBAR level, and they are not one single number. They depend on your filing status and whether you live in the United States or abroad. As a general guide, based on current IRS figures:

• If you live in the US and are single or file separately, you generally file if your specified foreign assets are worth more than 50,000 US dollars on the last day of the year, or more than 75,000 US dollars at any time during the year.
• If you live in the US and are married filing jointly, those levels are generally more than 100,000 US dollars on the last day, or more than 150,000 US dollars at any time during the year.
• If you live abroad, the levels are considerably higher. A single filer abroad generally files above 200,000 US dollars on the last day, or 300,000 US dollars at any time, and a married couple filing jointly abroad generally files above 400,000 US dollars on the last day, or 600,000 US dollars at any time.

These figures can change, so it is worth confirming the current numbers for your tax year before you rely on them. You can review the current thresholds on the IRS Form 8938 page. The point to take away is simpler than the list: Form 8938 kicks in at higher dollar levels than the FBAR, and where you live matters.

FBAR vs Form 8938, side by side

Note: this table is a plain-language summary, not the full rulebook. Each form has detailed instructions and exceptions. You can compare them directly on the IRS comparison chart, or ask a CPA to confirm which apply to you.

When someone may need to file both

This is the part that surprises people the most. Filing one form does not satisfy the other. The IRS is explicit that Form 8938 does not replace the FBAR. They are separate requirements with separate rules, and they can both apply to the same person in the same year.

A common pattern looks like this. Someone has a foreign bank account and a foreign brokerage account that together crossed the 10,000 US dollar mark, which points toward an FBAR. The same person also has enough in specified foreign assets to cross their Form 8938 level. In that case, both forms may be required, each filed in its own place: the FBAR with FinCEN, and Form 8938 with the IRS on the tax return.

The overlap is real, but the two forms are not interchangeable. That is exactly why they cause so much confusion.

What is not covered by either form

Just as important as knowing what to report is knowing what these forms generally do not reach. A few examples, based on current IRS guidance:

• Foreign real estate that you own directly is generally not reported on either form. If you hold that real estate through a foreign entity, though, the picture changes, because the entity itself can be a reportable asset.
• Foreign currency, precious metals, art, jewelry, and similar personal property held directly are generally not reported on either form.
• An account at a US branch of a foreign bank is generally not treated as a foreign account for these purposes.

These examples show why the details matter. Two people with similar-sounding situations can have very different filing requirements depending on how their assets are held.

What to do if you think prior years were missed

Many people only learn about the FBAR or Form 8938 after the fact. If you look back and realize prior years may have been missed, the most useful thing to know is that there are established paths for getting caught up, and the right one depends on your specific facts.

This is not a do-it-yourself moment for most people. Whether a particular catch-up path fits depends on details about your situation that are worth reviewing with a professional before you file anything. The goal is to get it right the first time, in the way that fits your circumstances.

One common path for getting caught up is the IRS streamlined program. Our guide to the Streamlined Filing Compliance Procedures explains who it is generally for and how it works.

How a CPA helps

Sorting out foreign reporting is less about the forms themselves and more about the judgment calls behind them: which accounts and assets count, which thresholds apply to your filing status and residency, whether both forms are in play, and how to handle prior years if needed.

A CPA who works in international tax can look at your actual accounts and assets, confirm the current rules for your tax year, and tell you which filings apply to you specifically. You can see how we approach this through our international tax services, and get the broader picture in our international tax guide. That turns a confusing pair of forms into a clear, short list of what you need to do.

Frequently asked questions

Is the FBAR the same as Form 8938?

No. They are separate forms with separate rules. The FBAR goes to FinCEN and reports foreign financial accounts. Form 8938 goes to the IRS with your tax return and reports a broader set of foreign financial assets. Some people need both.

Do I file the FBAR with my tax return?

No. The FBAR is filed separately with FinCEN through the BSA E-Filing System. It is not attached to your tax return. Form 8938, on the other hand, is filed with your return.

What is the dollar level for the FBAR?

In general, the FBAR comes into play when your foreign financial accounts add up to more than 10,000 US dollars at any time during the calendar year. It is a combined total across accounts, not a per-account figure.

Are the Form 8938 dollar levels the same as the FBAR?

No. Form 8938 levels are higher and depend on your filing status and whether you live in the US or abroad. Confirm the current figures for your tax year.

Can I have to file both forms?

Yes. Filing one does not cover the other. It is common for someone with foreign accounts to need both in the same year.

I think I missed prior years. What now?

There are established ways to get caught up, and the right path depends on your facts. It is worth reviewing your situation with a CPA before filing anything so it is handled correctly the first time.

Not sure which forms apply to your accounts?

Foreign reporting is one of those areas where a short conversation saves a lot of guesswork. If you are not sure whether the FBAR, Form 8938, or both apply to your accounts, request a consultation and we will help you sort out the filing path based on your specific facts. You can also learn more about how we help on our international tax CPA page.

This article is general information only and is not tax advice. Foreign reporting depends on your specific facts. Confirm the current rules for your tax year or speak with a CPA before you file.