The FBAR (FinCEN Form 114) and Form 8938 are separate reporting requirements that frequently overlap. The FBAR is filed directly with FinCEN via the BSA E-Filing System. A taxpayer must file an FBAR if the aggregate balance of all foreign financial accounts exceeds $10,000 at any time during the year. This report is submitted separately from the federal tax return.
In contrast, Form 8938 is filed with the IRS as an attachment to the annual Form 1040 to satisfy FATCA rules. The reporting thresholds for expats living abroad are significantly higher. Single filers abroad must submit Form 8938 if their specified foreign financial assets exceed $200,000 on the last day of the tax year or $300,000 at any time. For married taxpayers filing jointly abroad, these thresholds increase to $400,000 at year-end or $600,000 at any time.
While both forms target offshore assets, they involve different government agencies, thresholds, and definitions of what counts (for example, Form 8938 can cover foreign stocks or securities held directly, which the FBAR does not). Filing one does not replace the other, so many expats must submit both. Taxpayers should consider professional help to confirm their specific reporting requirements.