Yes. The Foreign Account Tax Compliance Act (FATCA) reporting thresholds for taxpayers living abroad are significantly higher than the domestic thresholds. For expats filing as single, the Form 8938 threshold is $200,000 on the last day of the tax year or $300,000 at any point during the year. For married couples filing jointly, these thresholds double to $400,000 at year-end or $600,000 at any time. Expats should confirm they are not mistakenly applying the much lower domestic thresholds, which are $50,000 ($75,000 at any point) for single filers and $100,000 ($150,000 at any point) for those married filing jointly.
It is important to contrast FATCA requirements with the Foreign Bank and Financial Accounts Report (FBAR) rules. The FBAR filing threshold is a flat $10,000 aggregate across all foreign financial accounts at any point in the year. Because the FBAR threshold is much lower, a taxpayer may easily need to file an FBAR even when Form 8938 is not required.
Additionally, the filing mechanisms differ. Form 8938 is attached and filed directly with the annual Form 1040 tax return. The FBAR is filed separately with the Financial Crimes Enforcement Network (FinCEN). Since a taxpayer can be over one threshold but not the other, it is wise to evaluate both obligations independently or consider professional help to ensure full compliance.