FBAR and Form 8938 Thresholds for US Expat Clients: What Advisers Should Check

Published 30 October 2026 by Steffan Kharmaaiarvi, founder

US citizens and green-card holders who live abroad keep two US reporting duties for accounts outside the United States: the FBAR, filed with FinCEN, and Form 8938, filed with the tax return. Neither is a tax, both carry penalties when missed, and both are commonly missed by clients whose accounts all feel local. An adviser who holds the client's brokerage statements is well placed to notice. This note sets out the thresholds, a worked example and the points to check. It is decision support, not tax advice.

FBAR: over USD 10,000 at any time

A US person must file FinCEN Form 114 when the aggregate value of their foreign financial accounts exceeds USD 10,000 at any time during the calendar year (FinCEN, IRS).

• Aggregate and maximum. The test adds up each account's highest value during the year. Ten accounts that never held more than USD 1,500 each are reportable together.
• Brokerage accounts count, as do bank accounts and, generally, foreign pensions and insurance policies with a cash value.
• The plan exemptions cover US plans, such as IRAs and tax-qualified retirement plans. A UK ISA or SIPP, a Canadian TFSA or an Australian super account is reported like any other foreign account.
• Dates. Due 15 April, with an automatic extension to 15 October. It is filed electronically with FinCEN, separately from the tax return.

Form 8938: higher thresholds abroad

Form 8938 is filed with the return when specified foreign financial assets exceed the thresholds in the IRS instructions:

A taxpayer is living abroad when their tax home is in a foreign country and they are either a bona fide resident of a foreign country for a full tax year or present abroad for at least 330 full days in a 12-month period. An account at a US financial institution is not a specified foreign financial asset. Filing one form does not replace the other: the same account can belong on both.

The broker question

Several brokers operate through both US and non-US entities: Interactive Brokers, Charles Schwab, Fidelity and Vanguard, among others. Whether an account is foreign depends on the entity that holds it, which is printed on the statement, not on the brand. An account with a European Interactive Brokers entity is a foreign account; one with Interactive Brokers LLC in the US is not.

A worked example

A single US citizen who has lived in Germany for several years, and meets the living-abroad test, has three accounts. Round illustrative figures in USD:

• FBAR: the first two accounts alone reach USD 265,000 at their highest. An FBAR is due whatever the third account is.
• Form 8938: USD 250,000 at year end is above the USD 200,000 year-end threshold for a single filer abroad, so the form is due. If the Interactive Brokers account is held by a non-US entity, it is added too.
• Married filing jointly instead: USD 250,000 at year end and USD 365,000 at most, even with the third account, stay under USD 400,000 and USD 600,000. No Form 8938, but the FBAR is still due.

Common mistakes

• Treating local tax-advantaged accounts as exempt. The plan exemptions are for US plans.
• Using the year-end value for the FBAR. The test is the highest value during the year.
• Counting by brand. The entity on the statement decides, not the logo.
• Forgetting the other accounts. Bank accounts, a joint account with a non-US spouse and signature authority over an employer's account all count for the FBAR.
• Assuming one form covers the other. They are separate duties with separate thresholds.

How Borderfolio for Advisors handles it

For a client marked as a US person, the Cross-Border page adds a finding on accounts held abroad:

• Accounts outside the US, in USD. Accounts at brokers outside the US are summed and converted to US dollars.
• FBAR and Form 8938 flags. The total is compared with the FBAR threshold and with the Form 8938 thresholds for a filer living abroad, single and joint.
• Brokers to check. Accounts at brokers with both US and non-US entities, such as Interactive Brokers, Schwab, Fidelity and Vanguard, are listed with their value for checking against the statement rather than counted.
• Today's values, labelled. The finding uses today's values and says so; both tests also look at the highest value during the year.

Accounts come from the client's confirmed statements; see consolidating client portfolios across brokers.

Where the screen stops

• Bank accounts, foreign pensions with a cash value, insurance policies and assets outside the brokerage accounts on file are not included, and can change the answer.
• The year's maximum value and the Treasury year-end exchange rate used for the FBAR are not applied.
• Nothing is filed, US-person status is the adviser's entry, and penalties are not estimated.

Sources: FinCEN, Report Foreign Bank and Financial Accounts, IRS, Report of Foreign Bank and Financial Accounts (FBAR), IRS, Instructions for Form 8938.

Frequently asked questions

Does a brokerage account count for the FBAR?

Yes. Securities and brokerage accounts at a financial institution outside the US are foreign financial accounts. Their highest values during the year are added to the client's other foreign accounts for the USD 10,000 test.

Are a UK ISA or a Canadian TFSA exempt from FBAR reporting?

No. The FBAR exemptions for retirement plans cover US plans such as IRAs and tax-qualified plans. A foreign tax-advantaged account is reported like any other foreign account.

What are the Form 8938 thresholds for a US citizen living abroad?

For an unmarried taxpayer or one married filing separately, more than USD 200,000 on the last day of the year or more than USD 300,000 at any time. For married filing jointly, USD 400,000 and USD 600,000.

Is an Interactive Brokers account a foreign account?

It depends on the entity holding it, shown on the statement. An account with a non-US Interactive Brokers entity is foreign; one with Interactive Brokers LLC in the US is not. Borderfolio lists such accounts for checking rather than counting them.