Form 8938 and FATCA reporting thresholds

Form 8938 is the Statement of Specified Foreign Financial Assets, filed with your annual 1040 under the FATCA rules. It overlaps with the FBAR but is a distinct form with its own thresholds, and it goes to the IRS as part of your return rather than separately to the Treasury.

The thresholds for Americans abroad

Living outside the US raises the bar. For a taxpayer abroad, Form 8938 is generally required once specified foreign assets exceed $200,000 on the last day of the year, or $300,000 at any point during it, with the figures doubled for a married couple filing jointly. Those living in the US hit the form at far lower levels, which is why the residency point matters.

How it differs from the FBAR

The two are easy to confuse. The FBAR has a $10,000 aggregate threshold, goes to FinCEN, and covers accounts. Form 8938 has the much higher thresholds above, goes to the IRS with your return, and covers a wider set of assets including some foreign investments held outside an account. Crossing one threshold does not mean you have crossed the other.

Reporting, again, is not taxing

Like the FBAR, Form 8938 is disclosure. It tells the IRS what you hold; the tax, if any, comes from the income those assets produce and is handled elsewhere on the return. The penalty for not filing when required is significant, so the form is worth getting right even though it adds no tax by itself.

Form 8938 sits alongside the FBAR and is part of the FATCA regime.