Bona fide residence
A US citizen who has been a bona fide resident of a foreign country or countries for an uninterrupted period that includes an entire tax year.
GUIDE · 2025 ACCOUNTS
FBAR and Form 8938: what differs?
FBAR and Form 8938 have different thresholds, cover different assets and go to different places. Here they are side by side, for individuals with foreign accounts or assets.
AT A GLANCE
Two reports, side by side.
Filing one does not replace the other. Circumstances can require an FBAR, Form 8938, both, or neither.
| Topic | FBAR (FinCEN Form 114) | Form 8938 |
|---|---|---|
| What it is | FinCEN Form 114, a separate account report. | An IRS form reporting specified foreign financial assets. |
| Where it goes | Filed electronically with FinCEN (part of the US Treasury) through BSA E-Filing. Not attached to your tax return. | Attached to your federal annual return and filed with the IRS. |
| What it covers | Foreign financial accounts in which you have a financial interest or signature authority. | Specified foreign financial assets, including accounts and some investments held outside accounts. |
| Threshold | Combined value of the accounts exceeds $10,000 at any time during the calendar year, subject to exceptions. | Depends on filing status and whether you qualify as living abroad. See the threshold table below. |
| Signature authority only | Can trigger reporting, subject to exceptions. | Does not by itself require Form 8938; another reportable interest is needed. |
| If you file no income tax return | Still checked: it is filed separately and tested on account value. | Not required if you are not required to file an income tax return. |
| Foreign branch of a US bank | Can be reportable. | Excluded in the IRS comparison. |
| Values | Maximum value, in US dollars at the calendar-year-end exchange rate. | Maximum value, in US dollars at the year-end exchange rate. |
| Due date | For 2025: April 15, 2026, automatically extended to October 15, 2026. Both dates have passed. | Same date as your annual return, including applicable extensions. |
This guide focuses on individuals. Domestic entities have their own Form 8938 and FBAR rules.
FORM 8938
Thresholds depend on where you live.
For specified individuals otherwise required to file an income tax return. You meet the threshold if your total specified foreign financial assets exceed either the year-end amount or the any-time amount.
| Your situation | Last day of the tax year | Any time during the tax year |
|---|---|---|
| Living in the US, unmarried or married filing separately | More than $50,000 | More than $75,000 |
| Living in the US, married filing jointly | More than $100,000 | More than $150,000 |
| Qualifying abroad, unmarried or married filing separately | More than $200,000 | More than $300,000 |
| Qualifying abroad, married filing jointly | More than $400,000 | More than $600,000 |
Who counts as qualifying abroad
The higher limits require a foreign tax home plus one of two presence-abroad tests. An overseas address is not the test.
330 full days
A US citizen or resident present in a foreign country or countries at least 330 full days during any period of 12 consecutive months.
WHAT COUNTS
Where the two part ways.
Some holdings fall under one report and not the other.
Foreign branch of a US bank
An account at a foreign branch of a US financial institution can fall under FBAR, while the IRS comparison excludes it from Form 8938.
Shares outside an account
Foreign shares held outside a financial account can be specified Form 8938 assets. Foreign pensions and some insurance interests can also need consideration.
Signature authority alone
Signature authority alone can trigger FBAR reporting, subject to exceptions. Form 8938 needs another reportable interest.
Foreign real estate
Directly held foreign real estate is not a Form 8938 financial asset; an interest in a foreign entity that owns real estate can be reportable. This does not settle income-tax reporting for rent or a sale.
RECORDS AND DATES
What to keep, and when it is due.
Both reports use US-dollar values at the calendar-year-end exchange rate and report maximum values. A current account balance is not a substitute.
FBAR records the IRS lists
- Name on the account
- Account number
- Bank name and address
- Account type
- Maximum value during the year
FBAR records generally must be kept for five years from the FBAR due date. Special rules apply to employees reporting authority over employer accounts.
Due dates
Dates as of 22 October 2026
| Report | Date | Status |
|---|---|---|
| FBAR, calendar year 2025: due date | April 15, 2026 | Passed |
| FBAR, calendar year 2025: automatic extension (no request needed) | October 15, 2026 | Passed |
| FBAR, signature authority only: certain people with only signature authority, and no financial interest, over certain foreign accounts (FinCEN notice FIN-2025-NTC3) | April 15, 2027 | Upcoming |
| Form 8938 | Your annual return's due date, including any applicable extensions | Follows your return |
Check IRS and FinCEN guidance for disaster or other special relief. Check the 2025 filing calendar
WHAT WE PREPARE
Limited Form 8938. FBAR prepared separately.
Limited Form 8938 is part of the Investor plan. The FBAR is prepared and e-filed separately, at its own price.
Investor
$199per federal returnUSD
- Everything in Premier
- Investment sales, with or without Form 1099-B
- Rental and royalty income, US or foreign
Limited Form 8938 preparation
Included in the Investor plan for eligible 2025 federal returns. Form 8938 covers supported account and asset summaries, the income from those assets on your return (Part III), and assets already reported on Form 3520 or 3520-A (Part IV). Cases we cannot complete are refused by name rather than guessed.
FBAR (FinCEN Form 114)
We prepare FBARs separately from your federal return and, when you ask us to, e-file them with FinCEN through the BSA E-Filing System for $59 per person, not in the plan price. Preparing your federal return does not itself file FinCEN Form 114. Form 8938 does not replace FBAR.
PFIC reporting (Form 8621) is in the Investor plan, with limits. Foreign corporation or partnership reporting (Forms 5471 and 8865) is not included in the plans.
Does filing Form 8938 cover my FBAR?
No. Filing one does not replace the other. Depending on your circumstances you may need an FBAR, Form 8938, both, or neither.
Is the $10,000 FBAR limit per account?
No. It is a combined-account check, not a $10,000 allowance per account, so several smaller accounts can cross the total. Check the exceptions in the full guidance.
Do the Form 8938 amounts change the FBAR threshold?
No. They apply only to the total specified foreign financial assets covered by Form 8938. The FBAR test stays at more than $10,000 combined.
My account earns no income. Can I skip the FBAR check?
No. The FBAR is filed separately from the income tax return and is tested on account value, so an account producing no taxable income does not remove the FBAR check. Check the exceptions in the official guidance.
What counts as signature authority for the FBAR?
Authority to control the disposition of the assets in the account by direct communication with the financial institution.
Does this guide cover businesses and other entities?
No. It focuses on individuals. Domestic entities have their own Form 8938 and FBAR rules.
Official sources
- IRS: Comparison of Form 8938 and FBAR requirements (opens in a new tab)
- IRS: Report of foreign bank and financial accounts (FBAR) (opens in a new tab)
- FinCEN: Report foreign bank and financial accounts (opens in a new tab)
- FinCEN: Notice FIN-2025-NTC3 (December 8, 2025) (opens in a new tab)
- IRS: Instructions for Form 8938 (opens in a new tab)
- IRS: Basic questions and answers on Form 8938 (opens in a new tab)
- IRS: Summary of FATCA reporting for US taxpayers (opens in a new tab)
- IRS: About Form 8938 (opens in a new tab)
Last reviewed 22 October 2026
BEFORE YOU START
See which forms we can prepare.
Form-by-form coverage for eligible 2025 federal returns, including what is not in the plans.
Check form coverage