FBAR vs Form 8938: what is the difference?
Short answer
FBAR is the everyday name for FinCEN Form 114, Report of Foreign Bank and Financial Accounts. It reports qualifying financial accounts located outside the United States to the Treasury's Financial Crimes Enforcement Network (FinCEN), using its separate, free BSA E-Filing website—not your federal tax return.Source 1Source 3
Form 8938, Statement of Specified Foreign Financial Assets, is an IRS information form under the FATCA rules. Eligible taxpayers attach it to their annual U.S. income-tax return to disclose specified foreign financial assets. It is not the FBAR, and one form does not replace the other.Source 1Source 2
A person with a foreign bank account might need neither form, just FBAR, just Form 8938 for other assets, or both. Decide separately: what assets do you have, who owns them, and does each form's own filing test apply?Source 1Source 2Source 3
The two forms in plain English
FinCEN Form 114 (FBAR): a Bank Secrecy Act report of certain foreign financial accounts. It includes foreign bank, brokerage and other covered accounts in which a U.S. person has a financial interest or signature/other authority. The common FBAR trigger is a combined account value of more than $10,000 at any point during the calendar year.Source 1Source 3
IRS Form 8938: an attachment to a federal income-tax return reporting specified foreign financial assets. It may include foreign financial accounts, but also certain directly held foreign shares, bonds and interests in foreign entities that are not held in a financial account. It does not use the $10,000 FBAR test.Source 1Source 2
Where, when and how do I submit each?
FBAR (Form 114) goes directly to FinCEN's BSA E-Filing System and is normally due April 15 after the reporting year, with an automatic extension to October 15. You do not attach the FBAR to Form 1040. See how to file an FBAR yourself and FBAR deadlines.Source 1Source 3
Form 8938 goes to the IRS as part of the relevant annual income-tax return, such as Form 1040, if you are required to file Form 8938. Its due date follows that tax return (including its applicable extensions). If you are not required to file an income tax return, you do not file Form 8938.Source 1Source 2
How do I check the different reporting thresholds?
For FBAR, check the combined value of all reportable foreign financial accounts. The filing threshold is more than $10,000 at any time during the calendar year; individual accounts below $10,000 may still have to be listed. Read the aggregate threshold guide.Source 1Source 3
For Form 8938, the threshold depends on where you live and how you file your tax return. Living outside the United States for Form 8938 purposes has its own tests based on your tax home and your foreign residence or physical presence; a foreign mailing address alone doesn't qualify. You file if your specified foreign financial assets are worth more than the first amount below on the last day of the tax year, or more than the second amount at any time during the year.Source 1Source 2
- Living in the United States, unmarried or married filing separately: more than $50,000 or more than $75,000.Source 1Source 2
- Living in the United States, married filing jointly: more than $100,000 or more than $150,000.Source 1Source 2
- Living abroad, unmarried or married filing separately: more than $200,000 or more than $300,000. Each spouse filing separately applies these amounts to their own assets.Source 1Source 2
- Living abroad, married filing jointly: more than $400,000 or more than $600,000.Source 1Source 2
- Specified domestic entities: more than $50,000 or more than $75,000.Source 1Source 2
What counts on one form but not necessarily the other?
An account held at a foreign broker typically raises an FBAR question and may also fall under Form 8938. Directly held foreign-company shares outside a financial account may create a Form 8938 obligation but are not themselves a foreign financial account for FBAR. Foreign pension arrangements can also require separate analysis under both regimes.Source 1Source 2Source 3
Signature authority over an employer account you don't own can require an FBAR. It is not reported on Form 8938 unless you also have an interest in the account. Some accounts and assets have exclusions and special rules on one form only, so check each form separately.Source 1Source 2
Two examples of choosing the right form
Example 1: A U.S. person has $18,000 in an otherwise reportable foreign checking account. $18,000 is above the FBAR threshold but below every Form 8938 threshold. This person files an FBAR but, with no other foreign assets, not Form 8938.Source 1Source 2Source 3
Example 2: A qualifying filer has an investment in foreign-company shares held directly rather than through a bank or brokerage account. The shares are not a foreign financial account, so they don't go on the FBAR. They can be specified foreign financial assets for Form 8938, subject to that form's threshold and exceptions.Source 1Source 2
Related questions
What is FinCEN Form 114?
What does Form 8938 actually report?
Do I need both an FBAR and Form 8938?
Is Form 8938 the same as FATCA?
If I report an account on my income-tax return, can I skip FBAR?
Does $10,000 apply to Form 8938?
Are foreign brokerage accounts covered by both forms?
What if I have foreign shares but no foreign bank account?
Do I file Form 8938 if I do not file a U.S. income-tax return?
Next pages
Sources
Official sources used for this page.
Source 1: IRS, Comparison of Form 8938 and FBAR requirements (opens in a new tab)
Side-by-side comparison of filing destination, scope, thresholds, filers and signature-authority accounts.
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Source 2: IRS, Instructions for Form 8938 (opens in a new tab)
Official Form 8938 instructions, thresholds, the income-tax-return condition and exceptions.
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Source 3: IRS, Report of Foreign Bank and Financial Accounts (FBAR) (opens in a new tab)
Core FBAR filing tests, reporting mechanics and exclusions.
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