Do I have to report my foreign bank accounts?
You kept an account in Mexico, Spain, or Colombia after moving to the US — and nobody told you the IRS wants to know. Two separate rules can apply: the FBAR (a low, $10,000 trigger) and FATCA Form 8938 (higher, and it depends on where you live). The penalties for missing them are brutal, and the filing itself is free. Check exactly which ones apply to you.
Your foreign accounts
Your two tests
Worked examples
Single nurse in Chicago with a Bancomer account
What you must file: FBAR
You cross the FBAR line (over $10,000 combined), but you're under the higher Form 8938 thresholds for your situation.
⚠ File the FBAR. It goes to FinCEN (not your tax return), due April 15 with auto-extension to Oct 15. No tax — just reporting.
Your two tests
- FBAR trigger (any-time aggregate over $10,000): YES — your peak $38,400 is over $10,000
- Your Form 8938 thresholds (US resident, single/MFS): over $50,000 last day, or over $75,000 any time
- 8938 last-day test: Not met — $27,900 at/under $50,000
- 8938 any-time test: Not met — $38,400 at/under $75,000
Married couple in Texas after selling a house in Spain
What you must file: Both
You cross both lines: file the FBAR (FinCEN Form 114) and Form 8938 with your return. They're separate — doing one doesn't cover the other.
⚠ File both. The FBAR goes to FinCEN by April 15 (auto-extended to Oct 15); Form 8938 attaches to your Form 1040. No tax on either — but penalties for skipping are $10,000+.
Your two tests
- FBAR trigger (any-time aggregate over $10,000): YES — your peak $268,000 is over $10,000
- Your Form 8938 thresholds (US resident, MFJ): over $100,000 last day, or over $150,000 any time
- 8938 last-day test: Met — $214,500 over $100,000
- 8938 any-time test: Met — $268,000 over $150,000
US couple living in Guadalajara, large peso savings
What you must file: FBAR
You cross the FBAR line (over $10,000 combined), but you're under the higher Form 8938 thresholds for your situation.
⚠ File the FBAR. It goes to FinCEN (not your tax return), due April 15 with auto-extension to Oct 15. No tax — just reporting.
Your two tests
- FBAR trigger (any-time aggregate over $10,000): YES — your peak $412,000 is over $10,000
- Your Form 8938 thresholds (living abroad, MFJ): over $400,000 last day, or over $600,000 any time
- 8938 last-day test: Not met — $268,000 at/under $400,000
- 8938 any-time test: Not met — $412,000 at/under $600,000
Examples are recomputed whenever the underlying rates or data change; the date above is the last recompute.
How FBAR and FATCA work & data sources
FBAR (FinCEN Form 114) is the low bar. If you're a US person and the combined value of all your foreign financial accounts was more than $10,000 at any point in the year, you must file it — even if no single account hit $10,000. It goes to FinCEN's BSA E-Filing system, not with your tax return, and it's due April 15 with an automatic extension to October 15. There's no tax on it — it's pure reporting.
FATCA Form 8938 is filed with your Form 1040 and has higher thresholds that depend on where you live and how you file. Living in the US: single/MFS if assets exceed $50,000 on the last day or $75,000 any time; married filing jointly $100,000 / $150,000. Living abroad (bona fide resident all year, or 330+ days in a foreign country): single $200,000 / $300,000; married filing jointly $400,000 / $600,000. All thresholds are "more than" — exactly at the number doesn't trigger. Crucially, filing Form 8938 does not replace the FBAR; many people file both. Penalties are steep: FBAR non-willful up to about $16,500, Form 8938 $10,000 for failure to file.
Sources: IRS — FBAR ($10,000) · IRS — Form 8938 thresholds · IRS — 8938 vs FBAR
Frequently asked questions
My account in Mexico peaked at $12,000 but ended the year at $3,000 — do I file an FBAR?
Yes. FBAR looks at the highest combined value at any moment, not the year-end balance. $12,000 is over $10,000, so you file — even though it's back down to $3,000 now.
I have three accounts, each around $4,000 — none is over $10,000.
You still file. FBAR is about the combined total of all accounts. Three at $4,000 = $12,000 aggregate, over the line.
Do I owe tax on the money in these accounts?
The FBAR and Form 8938 are reporting forms — no tax on the balance itself. But income the accounts earn (interest, dividends, gains) is taxable on your US return like any other income.
Does filing Form 8938 mean I've done the FBAR too?
No — they're separate systems. Form 8938 goes to the IRS with your return; the FBAR goes to FinCEN. If you cross both thresholds, you file both.