Choose a tax professional who regularly handles both FBAR (FinCEN Report 114) and IRS Form 8938 matters, can explain why each form does or does not apply to your facts, and states in writing who prepares, reviews, submits and supports every filing. Verify the person’s credential and active PTIN, define the records and services included, agree on fees, and confirm how you will receive copies and post-filing help. A credential by itself does not prove experience with your particular accounts, entities, trusts or residency history.
Understand what you are hiring the professional to do
“Foreign account reporting” is not one form or one agency. Two U.S. reporting systems commonly appear in an individual’s planning:
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| Report | Filed with | What it covers | How it is submitted | Important timing or threshold information |
|---|---|---|---|---|
| FBAR (FinCEN Report 114) | Financial Crimes Enforcement Network (FinCEN), in the Treasury Department | Qualifying foreign financial accounts, based on the filer’s accounts, ownership or authority and other facts | Electronically through FinCEN; it is not an attachment to the federal income-tax return | It is a calendar-year report. The Taxpayer Advocate Service describes the due date as April 15 of the following calendar year. Confirm current-year instructions and exceptions. |
| Form 8938, Statement of Specified Foreign Financial Assets | Internal Revenue Service | Specified foreign financial assets when the applicable filing rules and thresholds are met | Attached to the federal income-tax return when required | For unmarried U.S. citizens and residents living in the United States, the IRS FAQ updated February 26, 2024, states thresholds of more than $50,000 on the last day of the tax year or more than $75,000 at any time. For married filing jointly in that same residence context, the figures are more than $100,000 on the last day or more than $150,000 at any time. |
The same account or asset can be relevant to both systems, but the definitions, thresholds and filing channels differ. Filing Form 8938 does not replace an FBAR that is independently required. A sound professional starts with your complete facts instead of asking only for one year-end balance.
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Build a fact inventory before interviewing anyone
Prepare a short inventory for each foreign account or asset. It lets a candidate demonstrate how they analyze your situation and exposes gaps before you sign an engagement letter.
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- Country and financial institution, account type and account number or other identifier.
- Whether you own the account, jointly own it, have a financial interest, or merely have signature or other authority.
- Highest value during the year, year-end value and the currency used in the statements.
- Dates an account was opened, closed, transferred or inherited.
- Foreign interest, dividend, capital-gain, withholding-tax and other income records.
- Interests in foreign corporations, partnerships, mutual funds, trusts, pensions or insurance products.
- Your filing status, U.S. residence or nonresidence, citizenship, immigration status and any expatriation history that may affect the analysis.
- Prior federal returns and FBARs, including years you believe may be missing, incomplete or inaccurate.
Do not send passwords or unrestricted access to financial accounts during the screening stage. Redacted statements and a written summary are usually enough for an initial conversation; provide complete records through the secure method the professional specifies after engagement.
Verify credentials, PTIN and representation rights
Active PTIN is the baseline for a paid preparer
A person paid to prepare federal tax returns must have an active IRS preparer tax identification number (PTIN). Ask for the PTIN and confirm that it is current for the filing year. A PTIN authorizes paid preparation; it does not establish expertise in international reporting, nor does it by itself grant broad authority to represent you before the IRS.
Know what the main credentials mean
| Credential | How it is described by the IRS | Representation scope | What you still need to verify |
|---|---|---|---|
| Enrolled Agent (EA) | Licensed by the IRS; subject to suitability checks, a three-part examination or qualifying experience, and continuing education | EAs have unlimited representation rights before the IRS | Experience with your foreign-account facts, current status and the exact services offered |
| Certified Public Accountant (CPA) | Licensed by a state board; requirements include examination, education, experience, ethics and continuing education | CPAs have unlimited representation rights before the IRS | Active state license, international-tax experience and whether the firm handles FinCEN filings |
| Attorney | Licensed by a state court or bar | Attorneys have unlimited representation rights before the IRS | Active license, tax practice focus and experience with reporting, disclosure or controversy work relevant to you |
| Other paid preparer | May have a valid PTIN without one of the credentials above, or may participate in a specified IRS qualification program | Representation rights can be narrower and depend on the person’s qualification and the matter | Education, training, PTIN, practical experience and exactly what the person may do if the IRS contacts you |
Verify an EA through the IRS, a CPA through the relevant state board and an attorney through the applicable state bar or court. Ask to see the credential and license number rather than relying on a logo or job title.
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The IRS Directory of Federal Tax Return Preparers with Credentials and Select Qualifications lists attorneys, CPAs, EAs and certain other credentialed or Annual Filing Season Program participants with valid PTINs. It is not a complete list of every valid paid preparer. A person may be absent because they do not hold a listed qualification, opted out, or have a new or changed entry that has not appeared yet. Treat a missing listing as a prompt to ask about education, training, PTIN and experience—not as automatic proof that the person is invalid. Likewise, directory appearance is not evidence of foreign-account specialization.
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Test for relevant experience, not just general tax experience
Ask about facts that resemble yours
Ask how often the professional handles cases involving the combinations that matter in your file: signature authority without ownership, joint accounts, foreign entities, trusts, expatriate or residency questions, inherited assets, and years with possible nonfiling. The official rules do not prescribe a minimum number of FBAR or Form 8938 cases, so a candidate should explain the type and complexity of work they perform rather than quote an invented “required” case count.
Request a description of the analysis
A capable professional can describe the sequence they use: identify every account and asset, determine ownership or authority, calculate values in the required manner, test the applicable residence and filing-status rules, identify income-reporting consequences, and then map each item to FBAR, Form 8938, both or neither. They should be willing to explain assumptions and list information still needed.
Find out who actually does the work
In a larger firm, the person who sells the engagement may not prepare the forms. Ask for the preparer’s name, the reviewer’s name, their credentials and where responsibility sits if an issue is discovered later. A vague promise that “the team handles international matters” is not a substitute for named accountability.
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Before paying a deposit, obtain an engagement letter or similarly detailed statement of work. It should answer each of these questions:
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- Will the professional prepare your federal income-tax return, FBAR, Form 8938, or all three?
- Is electronic submission to FinCEN included, and will the professional prepare FinCEN Form 114a when you authorize a third party to file?
- Will the professional coordinate with another preparer if one person handles the income-tax return and another handles FBAR?
- Who reviews the completed forms, and what review is performed before submission?
- Which states, foreign forms, amended returns, extensions, disclosures or penalty work are excluded?
- What records must you provide, in what format and by what date?
- Will you receive a complete copy of every filed return and report, submission confirmation and workpaper or checklist that the firm normally provides?
- Who answers questions after filing season, for how long and at what additional rate?
If two professionals are involved, insist that one person be designated to reconcile the information. Separate engagements can otherwise produce inconsistent account names, balances or ownership descriptions.
Compare fees without losing sight of scope
Ask for a written fee structure tied to deliverables. A low quote for an income-tax return may exclude the FBAR, foreign-asset schedules, translation, amended years or follow-up with the IRS. An hourly arrangement can be reasonable for uncertain historical facts, but ask for a range, what triggers a higher range and how you will be notified.
The IRS warns against fees calculated as a percentage of a refund. Ask whether the fee changes if a refund changes, whether payment is required before filing, and whether a separate charge applies to FinCEN Form 114a, amended filings, notices or representation. Confirm whether secure document exchange, electronic filing and post-filing questions are included.
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Use a structured interview
- Describe the facts plainly. State every country, account type, ownership arrangement, authority, entity or trust connection, residence issue and prior filing concern. Do not wait until after signing to mention a difficult fact.
- Ask for the form-by-form analysis. Ask, “How will you determine whether each item triggers FBAR, Form 8938, both or neither?” Look for an explanation based on definitions, values, filing status and residence—not a yes-or-no answer based only on a balance.
- Confirm responsibility. Have the candidate identify who prepares, reviews and submits each form and whether the fee includes every required filing.
- Verify authorization. Request the credential, license information where applicable and active PTIN. Ask what representation the person can provide if the IRS sends a notice or examines the return.
- Inspect the record request. A serious preparer should ask for statements, maximum values, ownership details, foreign tax documents and prior filings. Someone who promises an instant answer without records is not demonstrating a reliable process.
- Review safeguards. Ask how documents are transmitted, who can access them and how the firm prevents data-entry errors. Confirm that you will review the completed forms before submission.
- Set communication expectations. Get a response channel, expected turnaround, availability after filing season and the rate for work outside the engagement.
- Compare written proposals. Put scope, exclusions, fee, deadlines and responsible people side by side. Choose the proposal you can understand, not merely the shortest one.
Records a competent preparer will need
Gather records early so the professional can test maximum values and ownership rather than relying on estimates.
- Complete annual statements for every foreign bank, brokerage and other financial account.
- Statements showing the highest balance or value during the year, not only the closing balance.
- Exchange-rate information or the method used to convert foreign currency.
- Documents identifying joint owners, beneficial owners, authorized signers and account closures.
- Foreign tax vouchers, dividend and interest statements, realized-gain reports and withholding records.
- Formation documents, ownership schedules and financial statements for foreign companies, partnerships or trusts.
- Pension, insurance and investment-contract statements where classification may be unclear.
- Copies and submission confirmations for prior federal returns, FBARs and Form 8938 filings.
- IRS or FinCEN notices, penalty letters and correspondence.
Keep an untouched copy of what you supplied. If a statement is corrected later, preserve both the original and corrected versions with the date you received each.
Red flags that justify walking away
- The preparer says Form 8938 automatically replaces FBAR, or treats the two reports as the same filing.
- The person will not provide a current PTIN, credential or license information.
- The quote is based on a refund percentage or changes without a written explanation.
- You are asked to sign a blank return or report, or told not to review the completed forms.
- The firm refuses to provide a copy of what was filed or will not identify who submitted it.
- The professional promises that an account is “too small to matter” without asking about ownership, authority, filing status, residence and maximum value.
- No one asks for statements, foreign tax documents or prior filings.
- The professional guarantees a particular tax result or penalty outcome before reviewing the facts.
- Refunds are directed to an account you do not control. The IRS recommends that taxpayers ensure refunds go to their own account.
Special situations to disclose at the first meeting
Foreign trusts and entities
Trusts, corporations and partnerships can create reporting questions beyond an individual account. Tell the professional whether you are a settlor, beneficiary, trustee, director, shareholder, partner or authorized signer, and provide governing documents. Ask whether the firm handles the related information returns or will coordinate with a specialist.
Expatriation or uncertain residency
Residence and filing status affect Form 8938 thresholds and the analysis of worldwide reporting. Provide immigration, treaty, move and expatriation dates, and ask whether the professional routinely handles those facts.
Past nonfiling, omissions or possible penalties
State which years may be incomplete before the professional quotes a fee. Ask whether the person handles delinquent filings, amended returns, disclosure procedures and IRS or FinCEN correspondence, or will refer that work to an attorney or other specialist. Do not assume that filing a current report resolves earlier years.
Review and submission safeguards
Taxpayers remain responsible for the information on their federal income-tax return even when a professional prepares it. The IRS states: “Taxpayers are ultimately responsible for all the information on their federal income tax return, regardless of who prepares the return.” Review names, account numbers, ownership, maximum values, currency conversions, filing status and every yes-or-no question before authorizing submission.
For FBAR, confirm that the report is being sent electronically to FinCEN rather than attached to the IRS return. If a third party files for you, complete and retain FinCEN Form 114a, Record of Authorization to Electronically File FBARs, as directed. Obtain the submission acknowledgment and a complete copy. For Form 8938, retain the filed federal return and attachments, including any version transmitted electronically.
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A practical decision matrix
| Question | Acceptable evidence | Do not settle for |
|---|---|---|
| Can this person handle my reporting? | Specific examples of similar account, ownership, entity or residency facts and a clear explanation of the analysis | “We do international tax” with no description of the work |
| Is the person authorized to prepare? | Current PTIN and verifiable credential or documented education and qualification | A business card, website badge or unverified title |
| Who owns each filing? | Named preparer, reviewer and submitter for the income-tax return, FBAR and Form 8938 | Unassigned responsibility or an unexplained handoff |
| What will it cost? | Written deliverables, exclusions, payment terms and additional-work rates | A refund percentage or an unexplained “starting at” price |
| What happens after filing? | Copy and confirmation policy, response channel and post-filing availability | No commitment once the return is transmitted |
Questions to ask before you hire
- How do you determine whether my accounts and other foreign assets trigger FBAR, Form 8938, both or neither?
- Who prepares and submits each filing, and is FBAR included in the engagement fee?
- What account statements, maximum balances, ownership details and foreign tax documents do you need?
- Who reviews the forms before filing, and will I receive complete copies and submission confirmations?
- What credential do you hold, is your PTIN current, and what representation can you provide if the IRS contacts me?
- What is the fee structure, what work is excluded and how can I reach you after filing season?
- Do you handle foreign trusts, entities, expatriation, past nonfiling or possible penalties, or will you coordinate with someone who does?
These questions help screen a professional; they are not individualized tax or legal advice. The official guidance does not rank one credential above another for every fact pattern and does not establish a universal minimum case count. Fit depends on the professional’s verifiable competence with your specific facts, a clearly assigned scope and a process you can audit.
Bottom line
Hire the professional who can separate FinCEN’s FBAR from the IRS’s Form 8938, walk through your ownership, authority, value, residence and filing-status facts, and put responsibility for every submission in writing. Verify the PTIN and credential, compare scope and fees, review the completed forms yourself, keep copies and confirm how follow-up will work. That process is more reliable than choosing from a directory listing or selecting the lowest quote.
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