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The three reporting tracks are different
Start by separating the forms. Schedule B is part of an applicable income tax return. The FBAR is a Treasury financial-account report filed electronically with the Financial Crimes Enforcement Network (FinCEN), outside the tax return. Form 8938 is an Internal Revenue Service attachment to the annual return for specified foreign financial assets when its separate conditions and thresholds are met.
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| Report | Where it is filed | Basic trigger | What it covers | Relationship to the other reports |
|---|---|---|---|---|
| Schedule B | Attached to the federal income tax return | The return asks about foreign accounts and related financial interest or authority | Foreign-account questions on the income tax return | It does not substitute for an FBAR |
| FBAR (FinCEN Report 114) | FinCEN BSA E-Filing System | Aggregate value of reportable foreign accounts exceeded $10,000 at any time during the calendar year | Foreign bank, securities and other financial accounts covered by the FBAR rules | Filed separately from the tax return; Form 8938 does not replace it |
| Form 8938 | Attached to the annual federal income tax return | A specified person has specified foreign financial assets, meets the applicable threshold and has an income-tax-return filing requirement | Specified foreign financial assets, which can be broader than bank accounts | It does not relieve an otherwise required FBAR |
Who should evaluate these obligations
This guide addresses U.S. citizens, resident aliens and other U.S. persons who own, control or have authority over foreign financial accounts. U.S. citizens and resident aliens generally remain subject to U.S. tax on worldwide income even while living abroad. The reporting question is separate from whether an account paid interest, dividends or other taxable income: an account can create a reporting obligation even when it produced no taxable income.
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Schedule B: the tax-return questions
What Schedule B asks
Schedule B includes questions about foreign financial accounts. A person with a financial interest in, or signature authority over, a foreign financial account may also have a separate FBAR obligation. Answering the Schedule B questions is part of preparing the applicable income tax return; it is not a way to transmit the FBAR to FinCEN.
How to use the answer
When preparing the return, identify every foreign account in which you had a financial interest or authority during the relevant year and answer the Schedule B questions as the form and instructions direct. If the facts also satisfy the FBAR test, prepare the separate FinCEN filing. Do not assume that checking a box on the return sends account details to FinCEN.
FBAR: when the $10,000 test applies
The aggregate threshold
An FBAR is generally required when the combined value of reportable foreign bank, securities and other financial accounts exceeded $10,000 at any time during the calendar year. The test is aggregate: $10,000 is not a separate allowance for each account. Add the relevant account values for the points in the year when the combined balance was highest. If the combined account assets were $10,000 or less throughout the year, the threshold rule does not require an FBAR.
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Accounts and authority that matter
The FBAR rules can apply when you have a financial interest in an account or signature or other authority over it. Ownership is therefore not the only fact to review. Include reportable foreign bank, securities and other financial accounts in the aggregate analysis, rather than looking only for accounts titled in your own name.
A specific exception
IRS guidance describes an exception for assets held in a U.S. military banking facility operated by a U.S. financial institution. Apply the exception only when the facility and institution meet the stated conditions; do not treat an ordinary overseas bank account as exempt merely because the account holder lives or works abroad.
How and when to file
File the FBAR electronically through FinCEN’s BSA E-Filing System. It is not attached to the federal income tax return. IRS guidance gives April 15 as the general annual due date; when that date falls on a weekend or legal holiday, the due date moves to the next business day. Check the FinCEN instructions for the applicable calendar year before filing.
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Form 8938: a separate asset-and-threshold test
Who files Form 8938
Form 8938 applies when all of the relevant conditions are present: you are a specified person, you have an interest in specified foreign financial assets, the assets exceed the threshold for your filing status and residence, and you have an income tax return filing requirement. The form is attached to that annual return.
Thresholds for taxpayers living in the United States
The following amounts are the thresholds stated in the applicable IRS guidance. “At year end” means the last day of the tax year; “at any time” means the maximum value during that tax year. The test uses “more than,” so an amount exactly equal to a listed figure does not exceed that figure. Tax year: the year for which you are filing; confirm the current Form 8938 instructions for that year.
| Filing status while living in the United States | More than this on the last day of the tax year | Or more than this at any time during the tax year |
|---|---|---|
| Unmarried | $50,000 | $75,000 |
| Married filing jointly | $100,000 | $150,000 |
| Married filing separately | $50,000 | $75,000 |
Thresholds for taxpayers living abroad
For this purpose, the IRS uses tax-home and presence or residence tests to determine whether a taxpayer lives abroad. The higher thresholds below apply only when those requirements are satisfied. Tax year: the year for which you are filing; confirm the current Form 8938 instructions for that year.
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| Filing status while living abroad | More than this on the last day of the tax year | Or more than this at any time during the tax year |
|---|---|---|
| Unmarried or married filing separately | $200,000 | $300,000 |
| Married filing jointly | $400,000 | $600,000 |
Form 8938 does not replace the FBAR
The IRS instructions state: “Filing Form 8938 does not relieve you of the requirement to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), if you are otherwise required to file the FBAR.” A taxpayer can therefore have to attach Form 8938 to the return and file an FBAR separately. Conversely, an FBAR filing does not automatically satisfy Form 8938.
Deadlines and filing destinations
Use the tax year and filing status that apply to your return, and verify dates in the current-year instructions. The general timing is:
| Filing item | General deadline or timing | Method |
|---|---|---|
| FBAR for the calendar year | April 15; next business day when April 15 is a weekend or legal holiday | Electronic filing through FinCEN’s BSA E-Filing System |
| Form 8938 | Due with the annual income tax return, including any applicable extension | Attach to the federal income tax return |
| Calendar-year individual income tax return | Generally April 15 for filing and payment, subject to weekend, holiday and extension rules | File under the normal income-tax-return process |
A qualifying U.S. citizen or resident alien abroad may receive an automatic two-month filing extension for the income tax return. The timing for paying tax can differ, so read the current IRS instructions. An extension of the income tax return does not turn the FBAR into an attachment; the FBAR remains a separate FinCEN filing with its own due-date rules.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.A practical filing workflow
- Identify the person and the year. Determine whether the filer is a U.S. citizen, resident alien or another U.S. person, identify the tax year, and establish filing status and residence for that year.
- Inventory every relevant account and asset. List foreign bank, securities and other financial accounts, the owner or owners, and any signature or other authority. Separately identify specified foreign financial assets that may fall within Form 8938 even if they are not ordinary bank accounts.
- Calculate the FBAR aggregate. Review values throughout the calendar year and determine whether the combined reportable-account value exceeded $10,000 at any point. Do not test each account in isolation.
- Evaluate Form 8938. Confirm that you are a specified person, have an interest in specified foreign financial assets, meet the applicable year-end or during-year threshold for your filing status and residence, and have a return filing requirement.
- Complete Schedule B with the return. Answer its foreign-account questions based on the accounts and authority identified in your inventory.
- Attach Form 8938 when required. Include it with the annual federal return and follow that return’s filing date or valid extension.
- Submit the FBAR separately. If the aggregate test is met, transmit FinCEN Report 114 electronically through the BSA E-Filing System. Do not attach it to the tax return or assume another form has transmitted it.
- Keep a support file. Retain account statements, ownership and authority information, maximum values used in the calculations, and copies of submitted forms so the figures can be explained if questions arise.
Worked examples
Several modest accounts can cross the FBAR threshold
A taxpayer has three reportable foreign accounts whose combined value reaches $11,000 on one day. Even if no single account exceeds $10,000 and none produces taxable income, the aggregate test is exceeded for that calendar year. The taxpayer should evaluate and, if required, file the FBAR; the Schedule B and Form 8938 analyses remain separate.
An account below $10,000 can still matter for another form
A single foreign account never exceeds $9,500. The FBAR threshold rule alone is not met, but the taxpayer must still answer the applicable Schedule B questions and determine whether the account, together with other specified foreign financial assets, causes Form 8938 thresholds to be exceeded.
Residence changes the Form 8938 analysis
An unmarried taxpayer living in the United States with specified foreign assets worth $80,000 at one point during the tax year exceeds the $75,000 during-year threshold. An unmarried taxpayer who meets the IRS definition of living abroad uses the higher $300,000 during-year threshold instead. The residence determination must be made under the applicable tax-home and presence or residence tests, not simply by counting days informally.
Joint filing has its own thresholds
A married couple filing jointly and living in the United States has specified foreign assets worth $120,000 at year end. That amount is above the $100,000 year-end threshold for that status, so Form 8938 should be evaluated. The FBAR question still uses the separate aggregate foreign-account test and calendar-year measurement.
Common errors to avoid
- Treating the three reports as one form. Schedule B, Form 8938 and the FBAR have different destinations and triggers.
- Applying the $10,000 amount to each account. The FBAR test combines reportable accounts.
- Assuming no taxable income means no reporting. Reporting can be required because of account value, ownership or authority even when the account generated no income.
- Attaching the FBAR to the return. The FBAR is submitted electronically to FinCEN through its BSA system.
- Using the wrong Form 8938 threshold. Filing status and whether the taxpayer meets the IRS definition of living abroad materially change the amounts.
- Assuming Form 8938 satisfies the FBAR. The IRS expressly says the obligations remain independent.
- Ignoring authority over an account. Signature or other authority can be relevant even without ordinary ownership.
- Relying on an outdated deadline. Check the instructions for the filing year, including weekend, legal-holiday and extension rules.
Situations that need individualized advice
This overview does not resolve every ownership and authority question. Jointly held accounts, accounts controlled for another person, signature authority without ownership, foreign entities, trusts, unusual financial products and delinquent or previously omitted filings can change the analysis. The FBAR and Form 8938 definitions do not operate identically, so copying the account list from one form to the other without checking scope can produce an incorrect filing.
Seek advice from a qualified tax professional familiar with cross-border reporting when the account history is incomplete, the filer has foreign entities or trusts, multiple people share authority, a prior FBAR or Form 8938 may have been missed, or the residence and filing-status thresholds are difficult to apply. Gather the account statements, ownership documents, authority details and prior returns before that consultation.
Quick Recap
Final checklist
- Have you identified the tax year, filing status and residence?
- Have you listed every foreign account, owner and person with signature or other authority?
- Did you test the combined reportable-account value at any point in the calendar year?
- Did you evaluate specified foreign financial assets against the correct Form 8938 threshold?
- Did you answer Schedule B on the income tax return?
- Did you attach Form 8938 when its conditions are met?
- Did you file any required FBAR separately through FinCEN?
- Did you verify the current-year deadlines and retain the calculations supporting each filing?
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