Form 8938 and FATCA reporting thresholds
Last checkedForm 8938 reports foreign financial assets on your US tax return. For Americans living abroad the thresholds are higher than for those in the US, and they are not the same as the FBAR. You may file both.
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.
Common questions
What is the Form 8938 threshold if I live abroad?
Higher than for Americans living in the US. For a taxpayer abroad, Form 8938 is generally required once specified foreign assets exceed 200,000 US dollars on the last day of the year, or 300,000 dollars at any point during it, with both figures doubled for a married couple filing jointly.
How is Form 8938 different from the FBAR?
Different form, different threshold, different recipient. The FBAR has a 10,000 dollar aggregate threshold, goes to FinCEN and covers accounts. Form 8938 has the much higher thresholds above, goes to the IRS with your 1040, 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, and many Americans abroad file both.
Does Form 8938 add any tax?
No. It is disclosure. It tells the IRS what you hold; any tax 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.
New and changed accounts, monthly.
Providers change who they will take, and nobody tracks it. Momo does. One email a month with what moved, plus the occasional note on tax and money for US citizens in the UK.
How Momo handles your address: privacy policy.
Accounts this affects
Savings accounts
Which UK savings accounts accept US citizens, which ask for extra paperwork, and which say no. Per-provider verdicts and the reporting rules behind them.
AccountsCurrent accounts
Which UK current accounts open for US citizens, which add strings, and which decline. Verdicts by provider, with the FATCA reason behind each one.
AccountsCash ISAs
A cash ISA is tax-free to HMRC but not to the IRS. Which UK providers open one for a US citizen, and why the US still taxes the interest.
AccountsStocks & shares ISAs
Most UK funds in a stocks and shares ISA are PFICs, which the US taxes punitively. Which providers accept US citizens, and why the wrapper rarely helps.
AccountsBrokerage accounts
Most UK investment platforms decline US persons. The ones that accept you, what they let you hold, and the PFIC trap on UK-domiciled funds.
AccountsMulti-currency accounts
Multi-currency and money-transfer accounts that accept US citizens for holding dollars and pounds, and what FBAR reporting they trigger.
AccountsSIPPs
A SIPP can work for a US citizen, but most providers restrict what you can hold. Which SIPPs accept you, and how the treaty protects the wrapper.
TaxFBAR
If your foreign accounts top $10,000 combined at any point in the year, you file an FBAR. What counts, when it is due, and what happens if you miss it.