Banking abroad & the FBAR: the two reports, plainly

Opening a bank account in your new country is one of the first practical steps of a move — and for a U.S. citizen or resident, it quietly creates two possible reporting duties back home. Neither is a tax. Both are routinely misunderstood, and both are explained here at the level a mover needs, from the official sources: the IRS’s own comparison of the two forms and FinCEN’s FBAR pages. Checked October 2026.

The FBAR: a report to FinCEN, not the IRS

The FBAR — formally FinCEN Form 114, Report of Foreign Bank and Financial Accounts — is filed with the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department. It is not filed with your tax return and not filed with the IRS.

• Who files: a U.S. person who has a financial interest in, or signature or other authority over, foreign financial accounts.
• The trigger: the aggregate value of those accounts exceeds US$10,000 at any time during the calendar year. It is a combined test — two accounts that together cross $10,000 on a single day are both reportable, even if neither does alone.
• What counts: the maximum value of financial accounts held at institutions physically located in a foreign country — bank and custodial accounts, including an account at a foreign branch of a U.S. bank. Foreign real estate held directly and foreign currency held in cash are not FBAR accounts.
• When and how: due April 15, with an automatic extension to October 15 — no request needed. Filed electronically through FinCEN’s BSA E-Filing System.

Form 8938: the FATCA report that rides with your tax return

The second duty comes from FATCA. Form 8938 (Statement of Specified Foreign Financial Assets) is attached to your annual income-tax return and covers a broader set of assets than the FBAR — foreign accounts plus certain non-account assets such as directly held foreign stock or an interest in a foreign entity. Its thresholds are far higher, and they depend on where you live and how you file (IRS figures):

The “living abroad” thresholds are the ones that apply to most Settled Overseas readers once the move is made — note they are the IRS’s tests, with their own residence conditions, not a simple mailing-address question.

Two forms, two agencies, no overlap trick

The point the IRS itself makes at the top of its comparison page: filing one form does not satisfy the other. Depending on your balances you may owe the FBAR only (common for a mover with one local account), both, or neither. Values are reported in U.S. dollars, converted at the end-of-year exchange rate for each form’s instructions. Both filings carry real penalties for non-filing — the IRS comparison page lists them, and FBAR civil penalties are adjusted annually for inflation — which is why this belongs on the moving checklist, not in the “later” pile.

The mover’s working habits

1. Track your maximum balances. The FBAR test uses the highest combined balance at any point in the year — keep the statements that prove it.
2. Expect your foreign bank to ask about U.S. status. Under FATCA, foreign institutions report U.S. account holders; account-opening paperwork asking for a U.S. taxpayer ID is the system working as designed, not a local oddity.
3. Calendar both dates. FBAR April 15 (automatic to October 15); Form 8938 travels with your return.
4. Ask before you restructure. Moving money between your own accounts does not remove a reporting duty, and signature authority over someone else’s account (a landlord’s, an employer’s, a relative’s) can create one. Confirm your facts with a cross-border tax professional — this page is the map, not the filing.

Official sources: IRS, “Comparison of Form 8938 and FBAR Requirements” (irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements); FinCEN, Report of Foreign Bank and Financial Accounts (fincen.gov). Figures checked October 2026.

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