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Form 8938 is used to report certain specified foreign financial assets under FATCA. It attaches to your U.S. tax return when the reporting rules apply.
Many expats confuse Form 8938 with FBAR. Understandable, because both deal with foreign financial reporting. Annoying, because they are not the same thing.
Form 8938 is attached to Form 1040. FBAR is filed separately through FinCEN. Some people may need one, both, or neither depending on the type and value of their foreign accounts and assets.
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Form 8938 reports certain specified foreign financial assets when the value of those assets is above the applicable reporting threshold. It is connected to FATCA reporting rules and is filed with your U.S. tax return.
This form is mainly about disclosure. It does not replace income reporting. If a foreign asset produced income, that income may still need to be reported elsewhere on the tax return.
Form 8938 may include foreign financial accounts and certain other foreign financial assets, depending on what you own and how those assets are held.
Source: IRS About Form 8938.
Form 8938 is attached to Form 1040 when it applies. It does not replace Form 1040, Form 2555, Form 1116, Schedule C, Schedule SE, or FBAR.
If the asset produced income, that income may also connect to other parts of the return, such as interest, dividends, capital gains, partnership income, or trust income. Form 8938 reports the asset. It does not automatically handle all income connected to the asset.
You may need Form 8938 if you are a specified individual and the value of your specified foreign financial assets is above the reporting threshold for your filing status and where you live.
The thresholds for Form 8938 are generally different from the FBAR threshold. They can also vary depending on whether you live in the United States or abroad and whether you file single, married filing jointly, or another status.
Foreign bank accounts, investment accounts, foreign securities, and other financial assets may need review if their values cross the applicable threshold.
Certain foreign partnership, trust, or entity interests may also need review. This is where foreign company ownership can make the filing picture more layered.
Do not assume that having a foreign account automatically means Form 8938 is required. Also do not assume that avoiding FBAR automatically means Form 8938 is not required. Different forms, different thresholds, different headache.
Form 8938 can include more than ordinary foreign bank accounts. The exact reporting depends on the type of asset, how it is held, and whether the reporting threshold is met.
This is why Form 8938 can feel broader than FBAR. FBAR focuses on foreign financial accounts. Form 8938 may reach certain foreign financial assets beyond bank accounts.
This is the part worth slowing down for. Filing one does not automatically cover the other.
| Question | Form 8938 | FBAR |
|---|---|---|
| Where is it filed? | Attached to your U.S. tax return. | Filed separately through FinCEN. |
| What does it focus on? | Specified foreign financial assets. | Foreign financial accounts. |
| Are the thresholds the same? | No. Form 8938 thresholds vary by filing status and whether you live abroad. | No. FBAR uses its own aggregate foreign account threshold. |
| Does one replace the other? | No. | No. |
In plain English: Form 8938 and FBAR are cousins, not twins. They hang around the same foreign-account neighborhood, but they do not do the same job.
Before starting Form 8938, gather your foreign account and asset records. You may need account names, institution names, countries, account numbers or identifiers, maximum values, year-end values, and income connected to the asset.
If values are in a foreign currency, you will need to convert them into U.S. dollars using a reasonable and consistent approach. The goal is to avoid guessing at account values when the form depends on thresholds.
If you own a foreign company, partnership interest, trust interest, or other foreign financial asset, do not assume this page is the only issue. Foreign entity reporting may need separate review.
Review Form 8938 and FBAR as two separate questions. Ask whether Form 8938 applies to your specified foreign financial assets, then ask separately whether FBAR applies to your foreign financial accounts.
Do not let the similar subject matter trick you into treating them as the same filing.
Form 8938 is a reporting form. It may be required even if the asset did not create a large U.S. tax bill.
This is one of the rude little features of foreign asset reporting: sometimes the filing requirement is about disclosure, not whether tax is due.
Form 8938 depends on asset values and thresholds. Gather maximum values and year-end values before deciding whether the form applies.
Guessing is a bad strategy here. The form is threshold-driven, so values matter.
Reporting an asset is not the same as reporting the income it produced. Interest, dividends, capital gains, partnership income, and other income may still need to be handled elsewhere on the return.
Form 8938 tells the IRS about certain assets. It does not magically file the rest of the return for you.
These are separate reporting requirements. Filing one does not automatically satisfy the other.
Form 8938 thresholds depend on filing status and whether you live abroad. Do not use the FBAR threshold as the Form 8938 threshold.
Form 8938 can include certain specified foreign financial assets beyond ordinary bank accounts.
Form 8938 is filed with the tax return when required. FBAR is filed separately.
Foreign partnership, trust, or entity interests may create additional review needs beyond ordinary personal bank accounts.
If an asset produced income, that income may need to be reported elsewhere on the tax return.
Form 8938 becomes more layered when you have foreign investment accounts, foreign business interests, foreign trusts, high-value assets, mixed ownership, assets spread across multiple countries, or assets that also produce income.
The way through it is to organize the asset list first. What do you own or control? Where is it located? What was the highest value? What was the year-end value? Did it produce income? Does FBAR also apply? Does any foreign entity form also apply?
If you are catching up on several years of returns, Form 8938 may need to be reviewed year by year. Asset values, account ownership, filing status, and residency status can change from one year to the next.
Start with the catch-up filing guide before trying to rebuild every foreign asset form one year at a time.
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Use these guides to understand the filing areas connected to Form 8938.
Review the separate foreign account reporting requirement filed through FinCEN.
See how Form 8938 attaches to the main U.S. tax return.
Review extra issues if you own or control a company registered outside the U.S.
Gather account, asset, income, and filing records before preparing the return.
See how common expat tax forms and reporting requirements connect.
Review options if prior-year foreign account or asset reporting was missed.
Disclaimer: This guide is for general educational purposes only and is not legal, tax, or accounting advice. U.S. expat tax rules can change and individual facts matter. Review current IRS, FinCEN, and other official guidance or consult a qualified tax professional before filing.