FBAR vs Form 8938: reporting foreign bank accounts

US persons with money or investments abroad face two reporting regimes that overlap but are not the same. Missing either carries heavy penalties, even when no tax is owed. This guide compares them side by side.

By Mirza Fahad Baig, Chartered Accountant. Reviewed by Muhammad Bilal, Chartered Accountant. Checked against official sources on . 3 minute read.

Short answer

FBAR vs Form 8938: both report foreign financial accounts, but they are separate filings. The FBAR, FinCEN Form 114, is filed by any US person, including a US LLC, whose foreign accounts total more than $10,000 at any time in the year. Form 8938 is filed with the tax return by individuals above higher thresholds, starting at $50,000. Many people file both.

At a glance

FBAR
FinCEN Form 114, filed with FinCEN
FBAR threshold
Over $10,000 combined at any time
Form 8938
Filed with the income tax return
8938 threshold, single US resident
Over $50,000 at year end or $75,000 at any time
Due
April 15; FBAR automatically extended to October 15
US LLCs
File FBARs themselves; 8938 rarely
FBAR vs Form 8938: reporting foreign bank accountsFBAR: FinCEN Form 114, filed with FinCEN; FBAR threshold: Over $10,000 combined at any time; Form 8938: Filed with the income tax return; 8938 threshold, single US resident: Over $50,000 at year end or $75,000 at any time; Due: April 15; FBAR automatically extended to October 15; US LLCs: File FBARs themselves; 8938 rarely.KEY FACTS AT A GLANCEFBAR vs Form 8938: reporting foreign bank accountsFBARFinCEN Form 114, filedwith FinCENFBAR thresholdOver $10,000 combined atany timeForm 8938Filed with the income taxreturn8938 threshold, single US residentOver $50,000 at year endor $75,000 at any timeDueApril 15; FBARautomatically extended toOctober 15US LLCsFile FBARs themselves;8938 rarelyChecked against official sourcesTax BakersFBAR vs Form 8938: reporting foreign bank accountsFBAR: FinCEN Form 114, filed with FinCEN; FBAR threshold: Over $10,000 combined at any time; Form 8938: Filed with the income tax return; 8938 threshold, single US resident: Over $50,000 at year end or $75,000 at any time; Due: April 15; FBAR automatically extended to October 15; US LLCs: File FBARs themselves; 8938 rarely.KEY FACTS AT A GLANCEFBAR vs Form 8938: reportingforeign bank accountsFBARFinCEN Form 114, filed with FinCENFBAR thresholdOver $10,000 combined at any timeForm 8938Filed with the income tax return8938 threshold, single US residentOver $50,000 at year end or $75,000 at anytimeDueApril 15; FBAR automatically extended toOctober 15US LLCsFile FBARs themselves; 8938 rarelyChecked against official sourcesTax Bakers
Key facts at a glance, as set out in this guide.

How do they compare?

FBAR (FinCEN Form 114)Form 8938
Who filesUS persons: citizens, residents, and US entities including LLCsSpecified individuals, and certain closely held US entities
ThresholdCombined foreign financial accounts over $10,000 at any timeSpecified foreign financial assets above thresholds that depend on filing status and residence
What is reportedBank, securities and other financial accounts, including signature authorityAccounts plus foreign stock, interests in foreign entities and some other assets
Where filedElectronically with FinCEN, separately from the tax returnWith the federal income tax return
DueApril 15, automatically extended to October 15With the return, including extensions

What are the Form 8938 thresholds?

TaxpayerLast day of the yearAt any time in the year
Single, living in the USOver $50,000Over $75,000
Married filing jointly, living in the USOver $100,000Over $150,000
Single, living abroadOver $200,000Over $300,000
Married filing jointly, living abroadOver $400,000Over $600,000

New residents should check both from the year residency starts. See your first US tax return after moving.

How do these apply to a US LLC?

A US LLC is a US person for FBAR, even if disregarded for income tax, so it files its own FBAR if its foreign accounts total more than $10,000 at any time. Multi-currency balances held with providers outside the US can count. Form 8938 is filed by individuals and a narrow group of closely held US entities with mainly passive income, so most operating LLCs do not file it. A non-resident owner of a US LLC is not a US person and does not file either for their personal accounts. See receiving international payments.

Both forms report accounts; neither creates tax by itself. Income from the accounts is still reported on the relevant tax return.

How do you file?

  1. List every foreign account

    And its highest balance in the year, converted at the year-end Treasury rate.

  2. Check the FBAR test

    Combined maximum balances over $10,000.

  3. File the FBAR online

    Through FinCEN's BSA E-Filing system.

  4. Check the Form 8938 thresholds

    And attach Form 8938 to your return if they are met.

What counts as a foreign financial account?

Bank and savings accounts, securities and brokerage accounts, and some pension and insurance policies with cash value, held at financial institutions outside the US. Accounts over which you have signature authority but no ownership, such as an employer's account, can also count for the FBAR. Accounts held at a US branch of a foreign bank are not foreign accounts.

What does an example look like?

A US resident has a savings account in Lahore with a highest balance of $8,000 and an account in London peaking at $4,000. The combined $12,000 exceeds $10,000, so an FBAR is required. Their foreign assets never exceed $50,000, so as a single filer living in the US they do not file Form 8938.

What are the penalties?

Non-willful FBAR violations can bring civil penalties for each report, adjusted for inflation; willful violations far more. Failure to file Form 8938 carries a $10,000 penalty, with more for continued failure after notice. Procedures exist for people who missed filings without wilful intent; using them before the IRS contacts you is far better.

Accounts outside the US?

We work out which reports apply to you and your LLC, file the FBAR and Form 8938, and bring past years up to date if needed.

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Questions people ask

What is the difference between FBAR and Form 8938?

The FBAR is filed with FinCEN by US persons with foreign accounts over $10,000. Form 8938 is filed with the tax return by individuals over higher thresholds, and covers more types of assets.

Does my US LLC need to file an FBAR?

Yes, if its foreign financial accounts total more than $10,000 at any time in the year, even if it is disregarded for income tax.

When is the FBAR due?

April 15, automatically extended to October 15.

Do I need to file both FBAR and Form 8938?

Often yes, if you meet both thresholds. Filing one does not replace the other.

Sources

Every fee, date and rule on this page was taken from these official and primary sources.

  1. FinCEN: Report of Foreign Bank and Financial Accounts (FBAR)
  2. IRS: Comparison of Form 8938 and FBAR requirements
  3. IRS: About Form 8938

Rules and fees change. If you are reading this long after October 1, 2026, confirm the figures with the source before you rely on them.

Banking and paymentsReceiving international payments into a US LLCFederal tax formsForm 3520: reporting gifts and money received from abroadForeign-owned and non-resident companiesDoes a foreign LLC owner need to file a personal US return

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This guide is general information. It is not tax or legal advice for your situation.