Free Tool Β· 2026 Rules

Form 8938 Threshold Checker

Form 8938 (FATCA) is the IRS form for reporting specified foreign financial assets β€” separate from FBAR. Thresholds vary by filing status and whether you live in the U.S. or abroad. This tool checks all four.

Check Your Form 8938 Threshold

Three inputs. The calculator applies the correct one of four thresholds (filing status Γ— U.S. vs. abroad) and tells you whether you need to file.

1Filing status

MFJ doubles the threshold. MFS (married filing separately) uses the “single” thresholds.

2Residence

Abroad = much higher thresholds. Specifically: meet the Physical Presence Test (330 days) or have your tax home + bona fide residence in a foreign country for the entire tax year.

3End-of-year total of all specified foreign financial assets (USD)

Aggregate value of: foreign bank/brokerage accounts, foreign stock/securities not held in a U.S. account, foreign mutual funds, foreign-issued bonds, interests in foreign partnerships/trusts/estates, foreign retirement accounts. Does NOT include: directly-held real estate, tangible assets, social security from foreign country.

4HIGHEST value of those assets at any time during the year (USD)

Form 8938 uses TWO threshold tests β€” end-of-year value OR highest-at-any-time value. Crossing either triggers filing. If you’re unsure, use the maximum month-end balance from your statements.

The four Form 8938 thresholds

Form 8938 thresholds depend on filing status AND residence. The IRS uses these specific dollar amounts (current per IRS Form 8938 instructions):

Filing statusResidenceEnd-of-year valueOR highest-at-any-time
Single / HoH / MFSU.S.$50,000$75,000
Single / HoH / MFSAbroad$200,000$300,000
Married filing jointlyU.S.$100,000$150,000
Married filing jointlyAbroad$400,000$600,000

Crossing either the end-of-year OR the highest-at-any-time threshold triggers Form 8938 filing. The IRS uses the OR test specifically to catch “deposit-then-withdraw” patterns where someone holds large assets briefly without it appearing on the year-end statement.

Form 8938 vs FBAR β€” they’re separate

The two most-confused forms in U.S. expat taxation:

FBAR (FinCEN 114)Form 8938 (FATCA)
WhatForeign bank account reportStatement of specified foreign financial assets
Filed withFinCEN (Treasury) β€” separate online filingIRS Form 1040 (attached to tax return)
Threshold$10,000 aggregate any time during year$50K–$600K depending on status/residence
What countsForeign financial accounts (bank, brokerage)Broader: accounts + foreign-issued securities + interests in foreign entities
Penalty$10K non-willful / $100K+ willful, per violation$10K + up to $50K additional + 40% accuracy penalty on tax
You can owe one but not the other. Example: a $15K foreign bank account triggers FBAR but is below the abroad single threshold for 8938. A $250K foreign retirement account that’s not in a regular bank account triggers 8938 (above abroad single threshold) but might not trigger FBAR (depending on whether the retirement account is considered a “financial account”).

What counts as a “specified foreign financial asset”

Form 8938 reportable assets include:

  • Foreign bank accounts (checking, savings, time deposits)
  • Foreign brokerage / investment accounts
  • Foreign mutual funds and ETFs (also typically PFICs β€” Form 8621)
  • Stock or securities issued by a non-U.S. person and not held in a U.S. account
  • Interest in a foreign entity (partnership, trust, estate)
  • Cash-value foreign life insurance or annuity contracts
  • Foreign retirement / pension accounts (with exceptions for some social-security-equivalent foreign government plans)

NOT reportable on Form 8938:

  • Directly-owned foreign real estate (a house in France is NOT a specified foreign financial asset, even if you rent it out)
  • Tangible personal property (foreign-held jewelry, art, cars)
  • Foreign social-security-equivalent payments
  • Assets held in a U.S. financial account (e.g., foreign stocks in your Schwab account)

How to determine residence (for the “abroad” thresholds)

Per IRS Form 8938 instructions, you’re considered “living abroad” for 8938 purposes if you meet either:

  • Tax home in a foreign country AND a bona fide resident of a foreign country for the entire tax year (the BFR test), OR
  • Physically present in a foreign country for at least 330 days during any 12-month period ending in the tax year (the PPT test β€” same as FEIE)

If you don’t meet either, you use the lower “U.S.” thresholds.

Penalty for not filing

Form 8938 failure-to-file penalty is $10,000 per failure. Continued failure after IRS notice can add up to $50,000 in additional penalties. Plus a 40% accuracy-related penalty applies to any underpayment of tax attributable to undisclosed foreign assets. Filing late voluntarily (before IRS contact) is far cheaper than waiting β€” see our Streamlined Filing Cost calculator for compliance pathways.

Educational only β€” not tax advice. Determining whether a specific asset is a “specified foreign financial asset” can be technical (foreign pensions, employer-provided retirement plans, and joint accounts with non-U.S. spouses all have nuances). Confirm specific asset classification with a qualified expat tax preparer before relying on the threshold result. False non-filing exposes the filer to substantial IRS penalties.
Sources checked β€” IRS Summary of FATCA Reporting for U.S. Taxpayers, Form 8938 Instructions (2025), IRS Form 8938 vs FBAR comparison, 26 U.S.C. Β§ 6038D.

Last reviewed: May 2026 by Ken Hoven. Editorial standards Β· Educational only, not tax advice Β· Spot an error?

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