FBAR and Form 8938 are separate foreign financial reporting requirements. Their covered persons, assets, thresholds, and filing procedures differ. You may need to file both.
Key Differences
| Item | FBAR | Form 8938 |
|---|---|---|
| Official name | FinCEN Form 114 | Statement of Specified Foreign Financial Assets |
| Filed with | FinCEN, a U.S. Treasury bureau | IRS |
| Main reporting scope | Foreign financial accounts | Specified foreign financial assets, including accounts and certain investments held outside accounts |
| Filing method | Electronic filing separate from the income tax return | Attached to the income tax return |
Reference: IRS — Comparison of Form 8938 and FBAR Requirements
FBAR Threshold
Generally, a U.S. person must file if foreign accounts in which they have a financial interest or signature authority exceed $10,000 in aggregate at any time during the calendar year.
The threshold applies to combined accounts, not each account separately. FBAR may be required even without an income tax filing obligation.
It is generally due April 15 of the following year, with an automatic extension to October 15.
Reference: FinCEN — Report Foreign Bank and Financial Accounts
Form 8938 Thresholds
For individuals living in the United States, filing is generally required when aggregate specified foreign financial assets exceed either applicable threshold below.
| Filing status | Year-end value | Value at any time during the year |
|---|---|---|
| Single or married filing separately | $50,000 | $75,000 |
| Married filing jointly | $100,000 | $150,000 |
Higher thresholds apply when specified overseas residence requirements are met. Being physically present in Japan is not sufficient by itself.
Generally, no Form 8938 is required without an income tax return filing obligation. Otherwise, it follows the return’s filing deadline, including applicable extensions.
Reference: IRS — Instructions for Form 8938
Does Filing One Replace the Other?
No. Review each requirement separately. The same Japanese account may appear on both forms, and accounts generating no income may still be reportable.
We review residency, asset types, ownership, signature authority, and balances to identify the necessary steps. Please exclude account numbers and confidential statements from your initial inquiry.
This is a general explanation for individuals. Exceptions and special rules may apply; filing requirements depend on individual circumstances.
Information reviewed: October 14, 2026
