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Free PDF · edition 2026-07

Am I non-compliant?

The 10-point US expat checklist

Ten yes/no questions that surface the reporting obligations US citizens and green-card holders abroad most often miss. Each point cites the official IRS, FinCEN, or SSA source, so you verify everything yourself — no trust in us required. Here are the first three:

  1. 01

    You file a US return every year — wherever you live

    Ask yourself: Did you file a US federal return for last tax year?

    US citizens and green-card holders file on worldwide income regardless of residence. Living abroad changes which forms you add — not whether you file. Many Americans abroad are behind without realizing it; that's common and usually fixable.

    Source: IRS — US citizens and residents abroad

  2. 02

    FBAR: the $10,000 trigger most expats miss

    Ask yourself: Did your non-US accounts, added together, ever exceed $10,000 at any point in the year?

    If yes — even for one day, even spread across several small accounts — you owe FinCEN Form 114 (FBAR). It's a separate report from your tax return, filed with FinCEN, not the IRS. Missing it is one of the most common and most fixable gaps.

    Source: FinCEN — Report of Foreign Bank and Financial Accounts

  3. 03

    Form 8938 is not the FBAR

    Ask yourself: If you filed the FBAR, did you also check the (higher) Form 8938 thresholds?

    FATCA adds a second report — Form 8938, attached to your 1040 — with its own, higher thresholds that depend on filing status and where you live. Filing one does not satisfy the other; plenty of expats owe both.

    Source: IRS — Summary of FATCA reporting (Form 8938)

In the full PDF

  • 04Foreign funds & ETFs are PFICs — each needs Form 8621
  • 05Retirement wrappers can hide PFICs
  • 06A FATCA letter means your bank already reports you
  • 07Joint accounts & a non-US spouse change the math
  • 08Self-employment abroad still means US self-employment tax
  • 09Behind 3+ years? There's a penalty-free path — while it lasts
  • 10Keep the four numbers every filing needs

Prefer to skip the reading? The free 2-minute risk scanner asks these questions interactively and emails you a personal report. Swiss-specific situation? Start at the Switzerland checklist.