FBAR vs. Form 8938: Do You Have to File Both?

Yes — if you meet the threshold for both the FBAR and Form 8938, you must file both, since they go to different agencies for different regulatory purposes. The FBAR is filed with FinCEN (a bureau of the Treasury Department) and covers foreign financial accounts; Form 8938 is filed with the IRS as part of your tax return and covers a broader category of foreign financial assets including foreign stock, partnership interests, and financial instruments — in addition to foreign accounts. The thresholds are very different: FBAR starts at $10,000 aggregate, while Form 8938 starts at $50,000 on the last day of the year (or $75,000 at any time) for single filers in the US, with higher thresholds for expats. In practice, anyone required to file Form 8938 almost certainly also needs to file an FBAR, since the FBAR threshold is lower — but someone might need to file an FBAR without hitting the Form 8938 threshold. The two forms overlap in coverage but each captures information the other doesn't.