Yes. Japanese financial accounts may require FBAR or Form 8938 reporting even without interest, dividends, or investment gains.
Income taxation and financial account reporting are separate requirements. No income does not automatically mean no reporting.
1. FBAR Depends on Accounts and Balances
A U.S. person generally reviews whether foreign accounts held through financial interest or signature authority exceeded $10,000 in aggregate at any time during the calendar year.
Non-interest-bearing deposits and investment accounts without trading activity may still be reportable. FBAR may be required even without an income tax return filing obligation.
Reference: IRS — Report of Foreign Bank and Financial Accounts
2. Form 8938 Also Requires Review Without Income
Form 8938 requirements depend on asset types and values, filing status, residence, and other conditions.
An account may be reportable without generating income. However, if no income tax return is required for the year, Form 8938 generally is not required. This differs from FBAR.
Reference: IRS — Instructions for Form 8938
3. Include Inactive Accounts
Include accounts you rarely use and accounts holding savings accumulated before your assignment.
An account with no interest or transactions during the year may still require reporting based on its balance and other conditions. Review maximum annual values, not just year-end balances.
4. Assess FBAR and Form 8938 Separately
The covered persons, assets, thresholds, and filing methods differ. Filing one does not replace the other.
Reference: IRS — Comparison of Form 8938 and FBAR Requirements
Information to Gather
- All non-U.S. bank and investment accounts
- Individual ownership, joint ownership, and signature authority
- Maximum annual and year-end balances
- Accounts opened or closed during the year
- Interest, dividends, and sales activity
- U.S. tax residency and prior reporting
We review income reporting and financial account reporting separately. Please provide only an overview initially; confidential account records should be shared through the method we specify separately.
This answer provides general information for individuals. Residency, account types, balances, and exceptions affect filing requirements.
Information reviewed: October 14, 2026
