Do I have to file both Form 8938 and the FBAR?
Most cross-border filers with foreign accounts do. They are separate obligations: different agency, different form, different threshold, different asset list, different due date and different penalty regime. Reporting the same account on both is not duplication, and satisfying one does nothing for the other. The FBAR goes to FinCEN and is not attached to the tax return, while Form 8938 is filed with the return. Because the thresholds and the asset lists are not the same, the contents of the two reports in one year need not match either, which is why copying one across to the other is the wrong way to prepare the second.
What is the FBAR reporting threshold?
The FBAR is required where the aggregate value of all your foreign financial accounts exceeds US$10,000 at any time during the calendar year, on the IRS figures we verified in August 2026. Two things in that sentence do the damage. It is an aggregate, so several small accounts can cross it while none of them is large on its own. And it is tested at any time during the year, so a single peak balance counts even if the account was emptied the next week and held nothing at the year end. The report is filed with FinCEN rather than attached to the return.
Do Form 8938 thresholds change if I live outside the US?
Yes, substantially. On the IRS thresholds verified in August 2026, a filer living abroad who is not filing a joint return reports where specified foreign financial assets exceed US$200,000 on the last day of the tax year or US$300,000 at any time during it. For a joint return the figures are US$400,000 and US$600,000. Living abroad has its own test: physical presence in a foreign country or countries for at least 330 days during a period of twelve consecutive months ending in the tax year. Fail that test for a year and the lower thresholds apply to it, which is what catches people in the year they move.
What are the Form 8938 thresholds if I live in the US?
On the IRS figures verified in August 2026, an unmarried filer living in the United States reports where specified foreign financial assets exceed US$50,000 on the last day of the tax year or US$75,000 at any time during it. Married filing jointly, the figures are US$100,000 and US$150,000. Married filing separately, they are US$50,000 and US$75,000. The two measurement points matter as much as the amounts, because there is a closing figure and a high-water figure, so assets sold or moved before the year end can still bring the form into play. Filing status changes the answer, and so does a move.
I filed the FBAR, does that cover Form 8938?
No. The two are answered to different agencies under different rules, and a complete FBAR leaves a missing Form 8938 exactly as missing as it was. The reverse is also true. This is the most common way a filer who has taken the trouble to get one report right still ends up with a gap, because the FBAR is the better known of the two and its threshold is far lower, so it tends to be the one discovered first. The safe assumption is that finding one report means testing yourself against the other, on that report's own threshold and its own asset list.
Are Form 8938 and the FBAR due at the same time?
Not necessarily, and they are not lodged in the same place. Form 8938 is filed with the income tax return, so it follows the return's timetable, including any extension of it. The FBAR is filed with FinCEN separately from the return, and has its own due date and its own extension rules. Treating them as one job with one deadline is how the second gets missed: the return is signed, the file is closed, and the report that was never part of the return is still outstanding. We diary them as two items for that reason, with the balances that trigger each.
Do dual citizens have to file US taxes if they live abroad?
Yes. US filing follows citizenship, not residence or where the income arose, and the obligation continues for as long as the citizenship does. Two further obligations travel with it and are keyed to account balances rather than income, so they can apply in a year with no US tax at all: the foreign bank account report to FinCEN, and the specified foreign asset statement with the return. Most people who discover a problem discover it there. See two returns as a dual citizen.
I have not filed for several years while living abroad — what are my options?
Both countries have routes back, and using one before they contact you is what preserves the relief. On the US side there are procedures aimed at taxpayers whose failure was not wilful, including one designed for people living outside the country, and separate procedures for late account reports and information returns alone. Canada has its voluntary disclosures programme and taxpayer relief for penalties and interest. Filing quietly and hoping is the one approach with no protection attached to it. See catch-up filing.
