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FBAR & Form 8938 threshold checker
A threshold met on a year whose return was never filed is a catch-up question, so this decides where the result sends you.
FBAR — FinCEN Form 114
not yet checkedThreshold screen: aggregate foreign financial accounts over $10,000 at any time during the calendar year.
Form 8938 — FATCA
not yet checkedFor this residence and filing status: over $200,000 at year end or over $300,000 at any time.
Next step
Enter a balance and say whether your returns are up to date; the result names the route that covers it. This checks numeric thresholds only — ownership, signature authority, asset scope, exceptions and exchange-rate choices are reviewed in the filing workflow.
Educational threshold screen, not tax or legal advice. FBAR covers foreign financial accounts; Form 8938 covers specified foreign financial assets under separate rules. Use the prescribed exchange-rate method for the form being prepared.
The Form 8938 thresholds, by reader
Four pairs, and the checker applies the one your answers select. Both tests read “more than”: the asset total must exceed the figure. The FBAR has one threshold for everyone — $10,000, aggregate, at any moment in the year.
| Filer | On December 31 | At any time in the year |
|---|---|---|
| Living abroad · single, MFS or head of household | more than $200,000 | more than $300,000 |
| Living abroad · married filing jointly | more than $400,000 | more than $600,000 |
| Living in the US · single, MFS or head of household | more than $50,000 | more than $75,000 |
| Living in the US · married filing jointly | more than $100,000 | more than $150,000 |
How the two tests differ
Who receives it. The FBAR (FinCEN Form 114) is filed online with FinCEN, on its own, whether or not you owe tax or even file a return. Form 8938 is attached to the Form 1040 — so a year with no return has no Form 8938, however large the assets.
What it covers. The FBAR covers financial accounts: bank, brokerage, a pension with a cash value, an insurance policy with a surrender value, an app balance held by a non-US entity, and any account you hold jointly or can sign on. Form 8938 covers specified foreign financial assets — those same accounts plus assets held outside any account: foreign stock or bonds held directly, an interest in a foreign partnership, trust or estate, a foreign-issued insurance or annuity contract.
How it is measured. The FBAR test is one number — the combined peak of every account, at whatever moment each peaked. Form 8938 has two — the total on December 31 and the total at its highest — and crossing either one triggers it. That is why the checker asks for a year-end figure when the peak alone sits between the two.
For a Revolut, Wise or N26 balance, the fintech account checker settles which entity holds it before either test is run; for the whole picture — the return, the two reports, PFICs, a catch-up — the US expat tax calculator runs every rule at once.
Common questions
- What is the Form 8938 threshold?
- It depends on where you live and how you file. Living abroad, a single filer (or married filing separately) must file when specified foreign financial assets exceed $200,000 on the last day of the year or $300,000 at any time during it; married filing jointly, $400,000 at year end or $600,000 at any time. Living in the US the thresholds are a quarter of those — $50,000 at year end for a single filer. The checker above applies the pair that fits your answers.
- Do I need Form 8938 if I already file an FBAR?
- Possibly — they are separate requirements with separate thresholds, and one does not satisfy the other. Form 8938 is filed with your tax return and covers a broader set of assets (including some, like a directly held foreign stock certificate or an interest in a foreign entity, that are not accounts at all); the FBAR goes to FinCEN and covers accounts. Most people who file one file both; a reader below the Form 8938 thresholds may still be well over the FBAR's.
- Why does the checker ask for a December 31 value?
- Because Form 8938 has two tests and the peak alone cannot always decide it. If your highest value during the year sits above the year-end threshold but below the any-time threshold, the answer turns entirely on what the assets were worth on December 31 — so the checker names that as the missing fact rather than guessing.
- Which value do I enter — the account balance or the asset value?
- Two different scopes. For the FBAR, the highest combined balance of every non-US financial account during the year. For Form 8938, the highest value of every specified foreign financial asset — which includes those accounts and also assets held outside an account, such as foreign stock or an interest in a foreign partnership or trust. The Form 8938 figure is therefore usually the same or larger.
- If I have no filing requirement, do I still file Form 8938?
- No. Form 8938 rides on the return: someone who is not required to file a return for the year has no Form 8938 requirement either, however large the assets. The FBAR is not conditional in that way — it is owed whether or not a return is.
- Which exchange rate do I use?
- The FBAR uses the Treasury's year-end rate for the currency. Form 8938 uses the same Treasury rate unless none is published, in which case another publicly available rate can be used and disclosed. Neither uses the yearly-average rate the return itself uses for income.
Before you rely on this result
What would settle it, and what covers it
Documents or facts needed
- • The highest balance of every non-US account during the year
- • December 31 values for the Form 8938 test
- • Institution and country for each account
- • Whether any account is joint or held with signature authority only
Recommended Atamatax route
Simple · $299 — prepares the FBAR worksheet and the return the accounts belong to.
Also possible: CPA Export ($199) · Complex ($799). The cheapest route that covers your facts is the right one; a package never covers more than one tax year.
How to read a status
- Likely:
- The facts entered meet the published test; confirm the inputs before acting.
- Possible:
- Some facts point this way and others are missing; more information decides it.
- Needs review:
- These inputs leave it open; a person should look before filing.
- Not currently indicated:
- Nothing entered triggers it this year; a changed fact can change the answer.
- Outside supported scope:
- This item is routed to a professional for preparation.
Scope. Threshold tests on the values entered; the FBAR is filed by you at FinCEN and the return through the route you choose. This is a computation on the answers you gave, not individualized tax advice.
Tool: /tools/fbar-8938
What changes the result
This answer changes if…
Whether an FBAR is due for a year
- …all your non-U.S. accounts together exceeded $10,000 at any single moment in the year — even for a day — the test is the aggregate peak, not a year-end balance and not per account.
- …you can sign on an account you do not own — an employer's, a parent's, a company's — signature authority is reportable even with no financial interest.
- …an account is joint with a spouse, or held through a company you control — joint and indirectly held accounts count toward your aggregate.
- …a product you did not think of as an account holds cash — a fintech wallet, a pension with a cash element, a cash-value insurance policy — the definition of a financial account is wider than a bank account.
- …the currency moved during the year — the maximum is converted at the Treasury year-end rate; a peak in a strong-currency month can cross the line.
Whether Form 8938 is due
- …you file jointly with a spouse — the joint thresholds are double the single ones.
- …you lived in the United States for part of the year — the abroad thresholds are four times the domestic ones; residence for the year decides which set applies.
- …you hold a specified asset outside any account — shares in a foreign company, a foreign pension, an interest in a foreign trust — those count toward the threshold even with no account balance.
- …the value at year-end differs from the peak — Form 8938 has two lines — a year-end test and an any-time test — and either one triggers it.
Each line names a fact that moves the result; what it moves to depends on the rest of your facts. Nothing here is a determination.
How Atamatax calculations are produced — the tests applied, statutory sources and review cadence — is documented in the methodology, and how the engine is validated in accuracy & review. Calculation fixes are recorded in the changelog.
Authorities cited
- 31 U.S.C. §5314 — 31 U.S.C. §5314 — Statutory basis for the FBAR (foreign financial account reporting)
- 31 CFR §1010.350 — 31 CFR §1010.350 — FBAR (FinCEN Form 114) filing requirement and $10,000 threshold
- FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
- IRC §6038D — IRC §6038D — Information reporting of specified foreign financial assets (Form 8938)
- IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
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.
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