FBAR & Form 8938 Filing Requirement Checker

FinCEN 114  •  IRC Section 6038D  •  FATCA Reporting Analysis
31 USC 5314IRC §6038DFinCEN 114Form 89382019 - 2026
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FinCEN 114 (FBAR) Form 8938 (FATCA)
1

Taxpayer Settings

These settings determine the applicable Form 8938 thresholds. FBAR thresholds do not vary by filing status or residency - the $10,000 aggregate rule applies to all U.S. persons.
2

What Counts? Account Type Reference

Bank AccountsChecking, savings, time deposits, CDs held at a foreign bank
Brokerage / Securities AccountsForeign accounts holding stocks, bonds, or other securities
Mutual Fund AccountsInterests in a foreign mutual fund or similar pooled investment fund held through an account
Pension / Retirement AccountsForeign employer pension plans and personal retirement accounts at foreign institutions
Life Insurance (Cash Value)Foreign-issued life insurance policies with a cash surrender value (e.g., whole life, universal life)
Annuity Contracts (Cash Value)Foreign annuity contracts that have a cash value or surrender value
Commodity / Futures AccountsForeign accounts used for commodity futures, options, or derivatives trading
Other Foreign Financial AccountsAny other account at a foreign financial institution in which you have a financial interest or signature authority
Foreign Stocks / Securities (No Account)Directly held foreign stocks, bonds, or securities not held through a financial account - Form 8938 only
Foreign Partnership InterestsCapital or profits interests in a foreign partnership - Form 8938 only
Foreign Hedge Funds & Private EquityInterests in foreign investment funds not held through a financial account - Form 8938 only
Other Specified Foreign Financial AssetsAny interest in a foreign entity or foreign-issued financial instrument not otherwise listed - Form 8938 only
Counts for both FBAR (FinCEN 114) and Form 8938
Form 8938 only (not reportable on FBAR)
Does not count for either form: Real estate held directly (not through a foreign entity); precious metals held directly; U.S. accounts even if holding foreign assets; foreign currency held directly; Social Security-type benefits from foreign governments.
3

Enter Foreign Accounts & Assets

Currency conversion: All amounts must be entered in U.S. dollars. For foreign-currency accounts, convert using the IRS Yearly Average Currency Exchange Rates for the applicable tax year (available at IRS.gov). For FBAR, use the Treasury Financial Management Service (FMS) year-end rates. Do not mix conversion methods within the same form.
Institution / Description Account Type Country Max Balance
(during year, USD)		 Dec 31 Balance
(year-end, USD)
Enter every foreign account and asset separately for the most accurate analysis. "Max Balance" is the highest value at any point during the year - used for FBAR. "Dec 31 Balance" is the year-end value - used for Form 8938.
4

Filing Requirement Analysis

Calculated Totals
Aggregate max balance (FBAR accounts)$0
Aggregate Dec 31 balance (FBAR accounts)$0
Max value - Form 8938 only assets$0
Dec 31 value - Form 8938 only assets$0
Combined max (FBAR + 8938-only)$0
Combined Dec 31 (FBAR + 8938-only)$0
◯
FinCEN 114 (FBAR)
Not Required
Aggregate maximum balance did not exceed $10,000.
◯
Form 8938 (FATCA)
Not Required
Applicable threshold not exceeded.
Filing Status & Residency Year-End Threshold At-Any-Point Threshold Your Dec 31 Total Your Max Total Required?
FinCEN 114 (FBAR) - Key Facts
Authority: 31 USC 5314; 31 CFR 1010.350
Threshold: Aggregate max > $10,000 at any point
Due Date: April 15; auto-extended to Oct 15
Filed Via: BSA E-Filing System (not with tax return)
Penalty: Up to $10,000/year (non-willful); up to $100,000+ or 50% of balance/year (willful)
Form 8938 (FATCA) - Key Facts
Authority: IRC Section 6038D; Treas. Reg. 1.6038D
Threshold: Varies by filing status & residency (see table)
Due Date: With Form 1040 (incl. extensions)
Filed Via: Attached to federal income tax return
Penalty: $10,000 for failure to disclose; up to $50,000 for continued failure after IRS notice
FBAR and Form 8938 are separate requirements. Meeting one threshold does not determine the other. Both may apply to the same account.
This tool is for informational purposes only and does not constitute tax advice. Tax determinations are fact-specific. Consult a qualified tax professional before making any filing or planning decisions. A tk.cpa resource - tk.cpa.
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