FBAR vs. Form 8938: Which One(s) Do You Actually File?

If you've got a bank account outside the US, you've probably run into two scary-sounding requirements: the FBAR and Form 8938. They get confused constantly — even by people who've been filing for years — because they overlap. But they are two separate obligations, to two separate agencies, with two very different thresholds. Here's how to tell which one (or both) applies to you.

The 30-second version

• FBAR = FinCEN Form 114. Goes to FinCEN (the Treasury's financial-crimes bureau), filed online. Triggered when your foreign accounts combined top $10,000 at any point in the year.
• Form 8938 = FATCA reporting. Goes to the IRS, attached to your Form 1040. Triggered at much higher thresholds — $200,000 at year-end (or $300,000 at any point) for a single filer living abroad.

You can easily owe one, both, or neither. A typical expat with a salary and one foreign checking account often crosses the $10K FBAR line but never gets near the $200K 8938 line — so FBAR only. A high-net-worth expat with foreign investments hits both.

Side by side

The mistakes people make

1. Assuming one covers the other. Filing your FBAR does nothing for your 8938 obligation and vice versa. They're separate filings to separate agencies.
2. Thinking real estate counts. Foreign property you own directly isn't reportable on either form — it's not a financial account. (If you hold it through a foreign company, the company interest can be reportable on 8938.)
3. Forgetting the income side. Any income from a reported asset still has to show up on the right schedule of your tax return. The reports don't replace reporting the income.

Quick self-check

• Foreign accounts ever topped $10,000 combined? → You likely owe an FBAR. (Our ClearFBAR tool walks you through it in 7 questions.)
• Foreign financial assets above $200K/$300K (single, abroad)? → You likely owe Form 8938 too. (See our Form 8938 guide.)
• Both true? → You file both.

Form 8938 in particular gets technical fast — what counts as a "specified foreign financial asset," how to value it, which entities trigger it. If you're near either threshold, a quick consult is worth it. Greenback's CPAs and IRS Enrolled Agents handle both.

This article is educational and is not tax or legal advice. Confirm current thresholds and penalties on the official IRS Form 8938 and FinCEN FBAR pages, or with a qualified tax professional.