A US person with foreign bank or brokerage accounts
The FBAR question is the aggregate highest value of foreign financial accounts during the calendar year, not whether the account paid interest.
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US Tax Planning & Compliance
FBAR and FATCA reporting for US persons
FinCEN Form 114 (FBAR) preparation and Form 8938 coordination for US persons with foreign accounts.
The value
An FBAR is FinCEN Form 114. Form 8938 is the FATCA form that goes with the tax return. Filing one does not file the other.
Prepare the FBAR from a complete account list, and prepare Form 8938 when that form is part of the agreed return, using the thresholds and due dates on the current IRS and FinCEN pages.
A clear split between FinCEN Form 114 and Form 8938
An account list with institution, country, and peak balance
An FBAR prepared for electronic filing with FinCEN
Form 8938 coordinated with the US return when it is in scope
Typical scope
What AT&F prepares, and what you list before the form is completed.
The final engagement is tailored to your facts. These are the core workstreams we use to define a useful, responsible scope.
01
FBAR (FinCEN Form 114) for US persons over the FinCEN threshold
02
A comparison with Form 8938 using the IRS comparison table
03
Account lists for individuals with accounts in India or elsewhere outside the United States
04
The records FinCEN and the IRS tell you to keep
Where this fits
Situations this page is written for.
An NRI or a cross-border founder with accounts at home
The same FBAR rules can apply if the person is a US person. The NRI page covers the US return. This page covers the account reports.
Someone who filed one form and not the other
The IRS comparison page says Form 8938 does not replace the FBAR. The FBAR is not filed with the tax return.
How the engagement moves
From the account list to the report that matches the official instructions.
- 1→
Decide which report is in view
We separate FinCEN Form 114 from Form 8938. The IRS comparison page is the reference, and it says to check each form’s current instructions.
- 2→
List the accounts
You provide the institution, the country, the type of account, whether you have a financial interest or signature authority, and the highest value during the year.
- 3→
Prepare the FBAR
The FBAR is prepared for FinCEN’s BSA E-Filing system. It is not attached to the Form 1040 or Form 1040-NR.
- 4
Prepare Form 8938 when it is in the engagement
Form 8938 is filed with the income-tax return when the IRS thresholds are met. Thresholds differ for people living in the United States and people living outside it, and for filing status. We use the figures on the current IRS comparison page.
What to have ready
A better start begins with the right information.
A list of foreign accounts and the institutions that hold them
Highest balances during the year, in the account currency
Whether you own the account or only have signature authority
The US return, if Form 8938 is also in scope
What you can expect
Useful work products, not just activity.
An account list and the assumptions on it
A prepared FBAR for BSA E-Filing
Form 8938 with the return, when that is in scope
A note of accounts or assets that still need a decision
Common questions
Before we begin.
The quickest way to get a firm answer is to share the facts that make your situation different.
Who must file an FBAR?+
The IRS and FinCEN say a US person must file if they have a financial interest in, or signature or other authority over, at least one financial account outside the United States and the aggregate value of those accounts exceeded $10,000 at any time during the calendar year. “US person” includes citizens, residents, and many entities. Read the current FinCEN and IRS pages. A few dollars over the threshold, even for one day, can matter.
When is the FBAR due?+
The IRS says the FBAR is due April 15 following the calendar year, with an automatic extension to October 15. You do not file a form to get that extension. FinCEN’s own due-date notice says the same. Disaster relief or a special extension for some signature-authority filers can change a date. Check the current IRS and FinCEN pages for the year you are filing.
How is Form 8938 different?+
The IRS comparison page says specified individuals and some domestic entities file Form 8938 with the income-tax return if specified foreign financial assets exceed the threshold for their situation. The published thresholds on that page are: living in the United States, more than $50,000 on the last day or more than $75,000 at any time during the year if unmarried or married filing separately, and more than $100,000 or $150,000 if married filing jointly; living outside the United States, more than $200,000 or $300,000 if unmarried or married filing separately, and more than $400,000 or $600,000 if married filing jointly. Specified domestic entities use more than $50,000 or $75,000. The same page says the table is current through its publication date and that you should check the form instructions for later changes.
What do the official pages say about penalties?+
The IRS says you may face civil and criminal penalties for FBAR reporting or recordkeeping failures, that the penalty depends on the facts, and that civil FBAR penalty maximums in Title 31 are adjusted annually for inflation. The comparison page states a Form 8938 penalty of up to $10,000 for failure to disclose, plus an additional $10,000 for each 30 days of non-filing after IRS notice, up to a stated maximum of $60,000, and says criminal penalties may also apply. Do not rely on a dollar figure from this website. Read the current IRS and FinCEN pages. This page does not describe a voluntary-disclosure or streamlined program.
Do you file late FBARs as a separate service?+
Not as a published service. If an FBAR is late, say so on the call. The IRS page on delinquent FBARs is the official starting point, and any engagement is scoped after the facts are known.
Do you publish a fee?+
No. Book a free call to get a quote.
Official sources
Check the current instructions.
The firm
A Delaware-licensed CPA practice, with a Dover headquarters.
Sagar Bajaj, Founder and CEO. Practicing CPA in the United States and Australia. License No. CA-0014602, issued by Delaware. The engagement lead for a particular matter is confirmed before work starts.
Book a free call to get a quote- Headquarters
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- License
- License No. CA-0014602, issued by Delaware
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Keep the next decision connected to the facts.
Practical perspectives that may help frame the next question. They are general information, not advice based on your particular records, facts or current rules.
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This page is general information, not personal tax, legal, or accounting advice. Who must file, and any penalty or due date, depends on the facts and on the current IRS, FinCEN, or Reserve Bank of India instructions. Check those sources, or book a call, before you file or pay.