A threshold screen, not a filing determination. Three answers cannot establish whether a specific account is reportable; the full checker and the account's own terms can.
The FBAR (FinCEN Form 114) is a U.S. report of non-U.S. financial accounts. It's filed electronically with FinCEN, separately from your tax return. For Americans in the UK it's easy to overlook — ordinary UK accounts can push you over the threshold without any single account looking large.
When an American in the UK has to file
Generally, when the combined value of your non-U.S. financial accounts exceeded $10,000 at any point during the year — the peak, not the year-end balance. Because it's a combined and currency-converted figure, a current account, a cash ISA, and a SIPP together can cross the line even if none is big on its own.
A common UK mistake: assuming an ISA is 'tax-free, so it doesn't count'. ISAs are tax-free in the UK, but for FBAR purposes they're generally still reportable foreign accounts.
What UK accounts may count
UK current and savings accounts.
Cash and stocks-and-shares ISAs.
SIPPs and other UK pension/investment accounts (account-level reporting).
Accounts where you have signature authority, even if you're not the owner.
FBAR vs Form 8938 (FATCA)
FBAR (FinCEN 114)
Form 8938 (FATCA)
Filed with
FinCEN, separately
Your tax return
Threshold
$10,000 combined peak
Higher; varies by status & residence
Scope
Financial accounts
Specified foreign financial assets
Many U.S. persons in the UK file both the FBAR and Form 8938. They overlap but have different thresholds and aren't the same filing.
UK products that count
ISAs — cash ISAs, stocks and shares ISAs and Lifetime ISAs are accounts like any other; their UK tax exemption does not matter to the FBAR. See the UK ISA and US tax.
NS&I Premium Bonds and savings — held with National Savings & Investments, the UK government's savings bank, and commonly treated as reportable.
SIPPs and personal pensions — a self-invested personal pension is an account with a provider and is generally reported (the SIPP and US tax). A defined-benefit workplace scheme with no account balance is a different question.
Junior ISAs and children's accounts — a child whose own accounts cross the threshold has their own FBAR; a parent can sign it for them.
UK banks and platforms report accounts held by US persons to HMRC under the UK–US FATCA agreement, and HMRC passes them to the IRS.
Not sure if your UK accounts cross the FBAR line?
The free Tax Risk Check helps you think through the combined-peak threshold and whether Form 8938 is also in play. Atamatax provides preparation support; this is not individualized tax or legal advice.
IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
IRC §6038D — IRC §6038D — Information reporting of specified foreign financial assets (Form 8938)
Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.
Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.
Frequently asked questions
Does my ISA count toward the FBAR even though it's tax-free in the UK?#
Yes — a UK ISA is generally a reportable foreign account for U.S. purposes and counts toward the FBAR's $10,000 combined peak, regardless of its UK tax-free status. Its investments may also raise separate PFIC questions.
The FBAR threshold is the combined peak across all your non-U.S. accounts, not per account, so several smaller accounts that add up to over $10,000 at any point in the year can trigger it.
No. The FBAR (FinCEN 114) goes to FinCEN with a $10,000 combined threshold; Form 8938 (FATCA) is filed with your return and has higher, status-dependent thresholds. Many people in the UK have to file both.
If you want the return and the account reporting prepared
Which route fits depends on a few facts, not on the balances. These are the common situations and the route the same rules give each one. Nothing is charged until you generate a package or accept a written quote.
Returns up to date, accounts over the thresholds, no non-US funds
Simple · $299 · Self-service software
The threshold is met and no non-US fund is in play: the Simple package prepares the return with the FBAR and Form 8938 logic inside it.
›What arrives, who prepares and checks it, and who files
A draft filing package for one tax year: Form 1040 and the supported schedules, Form 1116 inputs, FBAR/Form 8938 threshold logic and filing instructions — with every assumption disclosed.
The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.
Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.
You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.
Every return was filed; only the FBARs were missed
Simple · $299 · Self-service software
Your returns appear current and only FBARs were missed. Late FBARs are filed with FinCEN directly, with the reason for filing late and a reasonable-cause statement, so the annual package covers the return side. The threshold is met and no non-US fund is in play: the Simple package prepares the return with the FBAR and Form 8938 logic inside it.
›What arrives, who prepares and checks it, and who files
The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.
Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.
You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.
Non-US funds mean Form 8621 wherever a holding is a PFIC. The PFIC package screens each one from its domicile and drafts the form only where it applies.
›What arrives, who prepares and checks it, and who files
Everything in Simple plus up to 25 supported Forms 8621 — line-mapped worksheets until independent validation of the official PDFs completes — with QEF / mark-to-market / §1291 inputs per holding, fund-domicile classification with confidence shown, and the assumption log — for one tax year.
The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.
Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.
You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.
Streamlined Essential · $1,590 · Done-with-you case preparation, scoped first
Wages, pensions or bank accounts with no non-US funds is the standard catch-up scope: three returns, six FBARs, and the certification package.
›What arrives, who prepares and checks it, and who files
A Streamlined Foreign Offshore preparation package: up to three delinquent returns and six FBAR years as worksheets mapped to each year's official forms (official pre-filled PDFs only for tax year 2025), a document completeness check, the Form 14653 organiser, and filing instructions — one scoped quote, one payment.
A CPA or Enrolled Agent from the Atamatax team, assigned according to your case (its forms, countries and complexity), prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures, and signs as paid preparer. They are named on your case once they accept. If no professional has been assigned 7 days after payment, you choose between waiting and a full refund. You write your own statement of facts.
The CPA or Enrolled Agent assigned to your case reviews and answers for the work they sign; a person at Atamatax checks the file is complete before it reaches you.
You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.
When a professional's judgment is needed. Missed years beyond the FBARs, a foreign pension whose US treatment is unsettled, or an IRS letter about the accounts are read by a person before a route is chosen — the account reporting is the easy part; what the accounts earned is the part that needs judgment.
In every route the signatures and the filing stay with you or the accountant you choose; nothing is filed on your behalf. Written questions to hello@atamatax.com reach a person — we aim to reply within one business day. Who does what in each route.
Free preliminary result · a few questions
See which foreign-account filings may apply to you
The FBAR and Form 8938 have different thresholds, different definitions and different penalties. A few questions show which one — or both — your accounts point at, and what else rides along.
Enter each account's highest balance as a band. The checker runs the FBAR aggregate and the Form 8938 threshold for your filing status and where you live, and says which form — or both — the numbers point at. Free, no account.