IRS Form 8938 (FATCA): filing requirements, thresholds, and instructions
2026 filing season update: Filing your 2025 tax return? Form 8938 requirements remain unchanged for the 2025 tax year. If your specified foreign financial assets exceeded the applicable thresholds at any point in 2025, you must file Form 8938 with your return.
Deadline: April 15, 2026 – or October 15, 2026 with an extension. Qualifying US citizens and resident aliens living abroad receive an automatic extension to June 15, 2026.
Quick answer
If you hold financial assets outside the United States, IRS Form 8938 may require you to report them with your federal tax return. Tax Form 8938 is an information return – filing it does not create a separate tax liability on the reported assets. It reports what you hold, not what you owe.
| At a glance | |
|---|---|
| What it is | Form 8938, Statement of Specified Foreign Financial Assets – a FATCA reporting form |
| Who files | Specified individuals required to file a US income tax return whose foreign assets exceed the threshold |
| What is reported | Foreign financial accounts, foreign stocks and securities, interests in foreign entities, certain foreign insurance and pension contracts |
| Where it is filed | Attached to your federal tax return – Form 1040, 1040-NR, 1040-SR, or applicable entity return |
| Filing deadline | Same as your return: April 15, 2026 for the 2025 tax year, with extensions to June 15 or October 15, 2026 |
| Key penalty | $10,000 for failure to file, with additional penalties up to $50,000 after IRS notice |
What is Form 8938?
IRS Form 8938 is the individual reporting side of FATCA – the Foreign Account Tax Compliance Act, enacted in 2010. The FATCA Form 8938 requirement created a two-sided system: foreign financial institutions report US account holders to the IRS, and US taxpayers disclose their foreign assets on Form 8938, Statement of Specified Foreign Financial Assets.
The form is attached to your federal tax return and filed together with it – sometimes referenced as F8938 in tax software. You file it only when the reporting thresholds are met, and you have a return filing obligation.
Information return, not a tax bill
Filing Form 8938 does not create a separate tax liability. The form reports what you hold abroad, not what you owe. You may owe tax on income from those assets, but that tax is calculated on your return – Form 8938 itself is purely informational.
If you are not required to file a US income tax return for the tax year, you are not required to file Form 8938 – even if the value of your specified foreign financial assets exceeds the threshold.
US expats with multiple foreign-asset reporting obligations – FBAR, Form 8938, Form 5471, Form 3520 – should check each form’s requirements separately, since the triggers differ.
Why does the IRS care about foreign assets?
FATCA and Form 8938 are part of a global push for financial transparency. Under the FATCA Form 8938 rules, the IRS can cross-reference your return against data that foreign financial institutions report independently.
The enforcement works through three channels:
- Foreign-institution data matching. Under FATCA, foreign banks and financial institutions in countries with intergovernmental agreements report account balances and income data for US persons to the IRS. If your foreign bank reports an account and no Form 8938 or FBAR appears on the US side, the IRS sees a gap.
- Detection of unreported foreign income. Interest, dividends, and gains earned in foreign accounts are taxable on your US return. Form 8938 creates a paper trail linking the assets that produce that income.
- Cross-checking against related returns. The IRS matches Form 8938 data against FBAR filings, Form 5471 for foreign corporations, Form 8621 for PFICs, and other international information returns.
FATCA 8938 reporting is an information-reporting tool, not a separate tax. But failing to file it can trigger penalties that apply regardless of whether you owe any additional US tax.
Foreign financial institutions in countries with FATCA intergovernmental agreements report US account holder data to the IRS annually – creating a second paper trail the IRS can match against your return.
Form 8938 is not just for millionaires
The Form 8938 filing requirements apply to specified individuals who are required to file a US income tax return and whose specified foreign financial assets exceed the applicable threshold.
Many middle-income expats meet that threshold once they add up accounts they may not think of as investments.
Holdings that count toward the total include:
- A local checking or savings account at a foreign bank
- A foreign brokerage or securities account
- A foreign pension or retirement account, depending on its legal and financial characteristics
- A jointly held account, where your share of the value counts
- Foreign mutual funds or ETFs, which may also create separate PFIC reporting obligations
The threshold uses aggregate value – the combined total across all qualifying foreign assets, not the value of any single account.
Who needs to file Form 8938?
Three conditions must be met before the Form 8938 requirements apply: you must be a specified individual, you must be required to file a US return, and your specified foreign financial assets must exceed the threshold.
Specified individuals
The following categories of taxpayers qualify as specified individuals for Form 8938:
- US citizens, regardless of where they live
- Resident aliens for any part of the tax year
- Nonresident aliens who elect to file jointly with a US spouse
- Nonresident aliens who are bona fide residents of American Samoa or Puerto Rico
Certain domestic entities also file Form 8938. These include closely held domestic corporations and partnerships where at least 80% of the ownership is held by a specified individual and at least 50% of income or assets is passive.
The return-filing condition
You are not required to file Form 8938 if you do not have a US income tax return filing obligation for the tax year – even if your foreign assets exceed the threshold. This is the condition that many articles miss.
Any specified individual who should file Form 8938 but fails to do so faces a $10,000 (2025) penalty, even if no tax is owed on the underlying assets.
How the threshold test works
Your Form 8938 filing threshold depends on whether you file as single, married filing jointly, or married filing separately. It also depends on whether you meet the IRS definition of living abroad.
The IRS Form 8938 filing requirements apply regardless of whether the foreign assets produce income during the tax year. Holding the asset is enough if the value exceeds the threshold.
For a broader overview of which expat forms apply to your situation, see our US tax forms for expats guide.
Form 8938 filing thresholds
Each Form 8938 threshold depends on your filing status and whether you meet the IRS definition of living abroad.
You exceed the threshold only when the total value of your specified foreign financial assets is more than the applicable dollar amount – not equal to it.
The IRS uses two tests – a year-end value test and an any-time-during-the-year value test – and you must file if either test is met.
| Filing status | US residents – year-end | US residents – any time | Living abroad – year-end | Living abroad – any time |
|---|---|---|---|---|
| Unmarried | More than $50,000 (2025) | More than $75,000 (2025) | More than $200,000 (2025) | More than $300,000 (2025) |
| Married filing jointly | More than $100,000 (2025) | More than $150,000 (2025) | More than $400,000 (2025) | More than $600,000 (2025) |
| Married filing separately | More than $50,000 (2025) | More than $75,000 (2025) | More than $200,000 (2025) | More than $300,000 (2025) |
These thresholds have remained unchanged since 2011 and are not adjusted for inflation.
The Form 8938 threshold for married filing jointly doubles the unmarried amounts. On a joint return, both spouses’ specified foreign financial assets are combined for a single threshold test – even if only one spouse owns the accounts.
What “living abroad” means for these thresholds
The higher abroad thresholds apply only if you meet a specific IRS test. You must have a tax home in a foreign country and meet one of two conditions:
- You are a US citizen who is a bona fide resident of a foreign country for an uninterrupted period that includes an entire tax year.
- You are a US citizen or resident alien present in a foreign country for at least 330 full days in any 12 consecutive months ending in the tax year.
Living outside the US is not enough on its own. If you are unsure which test applies, see our bona fide residence vs. physical presence test guide.
What counts as a “specified foreign financial asset”?
Form 8938, Statement of Specified Foreign Financial Assets, requires you to identify each qualifying asset, its maximum value during the year, and the financial institution where it is held. The scope is broader than just a bank account.
Reportable assets
The following asset types are generally reported on Form 8938 when the threshold is met:
- Foreign financial accounts – checking, savings, deposit, and brokerage accounts held at a foreign financial institution
- Foreign stocks or securities not held through a US financial institution
- Interests in foreign partnerships, corporations, or trusts
- Foreign mutual funds and pooled investment vehicles
- Foreign pensions and retirement accounts, depending on their legal and financial characteristics
- Certain life insurance or annuity contracts with a foreign issuer that have a cash value
Assets that require closer analysis
Not every foreign asset fits neatly into the reportable or excluded category. Whether a foreign pension is a specified foreign financial asset depends on its particular legal structure, not just the word “pension.”
The same applies to certain foreign insurance products and profit-sharing arrangements.
If you reported a specified foreign financial asset on Form 3520, Form 3520-A, Form 5471, Form 8621, or Form 8865, you do not need to report it again in detail on Form 8938.
You must, however, identify the form on Part IV of Form 8938 and include the asset’s value when testing the threshold.
Difference between deposit and custodial account on Form 8938
A deposit account holds cash at a foreign bank. A custodial account holds securities or investments on your behalf at a foreign financial institution. Part V of Form 8938 asks you to check a box indicating which type each foreign account is.
| Deposit account | Custodial account | |
|---|---|---|
| What it holds | Cash – checking, savings, certificates of deposit, time deposits | Financial instruments – stocks, bonds, mutual fund shares, currency contracts, derivatives |
| Typical example | A euro savings account at a French bank | A brokerage account at a Swiss investment firm |
| Form 8938 treatment | Reported in Part V, box “Deposit” checked | Reported in Part V, box “Custodial” checked |
Which type is my account?
If the institution accepts deposits and your balance is cash, it is a deposit account. If the institution holds securities or investment products for you, it is a custodial account. Some accounts hold both – in that case, the institution’s primary function determines the classification.
Other foreign financial assets that are not held in an account at a foreign financial institution – such as a direct interest in a foreign entity or a foreign-issued insurance contract – go in Part VI of Form 8938, not Part V.
What foreign assets do not count for Form 8938?
Directly held foreign real estate is not a specified foreign financial asset. Neither is foreign currency held directly, meaning physical cash rather than a balance in a foreign bank account. Several other commonly misunderstood assets may also be excluded.
Generally excluded
The following assets are not specified foreign financial assets and do not count toward the Form 8938 threshold:
- Directly owned foreign real estate – the property itself is not reportable
- Foreign currency held as physical cash
- Social security-type benefits from a foreign government
- Assets held in a US-based financial institution, even if the underlying assets are foreign – for example, foreign stocks held through a US brokerage account
- An account maintained at a foreign branch of a US financial institution
Review carefully – not always excluded
These assets fall into a gray area and may require professional analysis:
- Foreign real estate held through a foreign entity – the entity interest is a specified foreign financial asset, and the real estate value counts toward the interest’s value
- A foreign pension with features that make it function like a financial account rather than a social security benefit
- A foreign trust where you are a beneficiary with a known interest value
- Crypto held at a foreign exchange – the IRS has not issued guidance on whether virtual currency is a specified foreign financial asset for Form 8938 purposes. FinCEN Notice 2020-2 addresses FBAR only, not Form 8938.
US citizens who own foreign real estate directly do not report the property on Form 8938 – but rental income, capital gains, and any entity structure used to hold the property may trigger separate reporting.
Some accounts that appear foreign may qualify for a FATCA reporting exemption – including accounts at a foreign branch of a US-based financial institution.
What’s the difference between Form 8938 and FBAR?
Filing Form 8938 does not satisfy your FBAR obligation, and filing an FBAR does not satisfy your Form 8938 obligation. The two forms serve different agencies, cover different asset scopes, and use different thresholds.
Forms 8938 and FBAR are separate requirements filed with different agencies – Form 8938 goes to the IRS with your tax return, while FinCEN Form 114 goes to FinCEN through the BSA e-filing system.
Form 8938 vs. FBAR comparison
An asset or account can require reporting on both forms. The forms have different rules, so you must check each one separately.
| Aspect | Form 8938 | FBAR – FinCEN Form 114 | Key takeaway |
|---|---|---|---|
| Purpose | Report specified foreign financial assets under FATCA | Report foreign financial accounts under the Bank Secrecy Act | Different laws, different scope |
| Filed with | IRS – attached to your tax return | FinCEN – filed electronically, not with your tax return | Two separate agencies |
| Who files | Specified individuals required to file a US return who exceed the asset threshold | US persons with a financial interest in or signature authority over foreign financial accounts exceeding $10,000 (2025) aggregate | FBAR applies to a broader group – no return-filing requirement needed |
| Asset scope | Broader – accounts plus foreign stocks, entity interests, pensions, insurance, instruments | Narrower – foreign financial accounts only | Form 8938 covers more asset types |
| Threshold | From $50,000 (2025), varies by status and residency | $10,000 (2025) aggregate across all foreign accounts at any point | FBAR triggers at a much lower amount |
| Deadline | With your return – April 15, 2026, with extensions | April 15, 2026, with automatic extension to October 15, 2026 | Similar deadlines, but FBAR has an automatic October extension |
| Penalties | $10,000 for failure to file, plus continuation penalties up to $50,000 | Up to $16,536 per non-willful violation – one penalty per FBAR filed, not per unreported account, under the Supreme Court’s 2023 Bittner ruling. Willful violations: the greater of $165,353 (2025) or 50% of the account balance per violation, assessed per account. | Both carry separate penalty exposure |
For a full side-by-side analysis, see our FBAR vs. Form 8938 guide.
Married couples should also check whether they can file FBAR jointly or need separate filings.
How to file Form 8938
Form 8938 is attached to your federal tax return. You cannot file it separately or submit it directly to the IRS as a standalone document.
If you e-file your return, Form 8938 is included electronically as an attachment. If you file on paper, attach the completed form to your return before mailing.
The instructions for Form 8938 explain how to identify reportable assets, determine maximum values, and convert foreign-currency balances to US dollars.
Filing steps
Follow these steps to complete and file Form 8938 with your return:
- Identify your reportable assets. List every foreign financial account, foreign security held directly, foreign entity interest, and foreign contract with a cash value. Include assets you closed during the year.
- Determine the maximum value of each asset during the tax year. This is not just the year-end balance. You need the highest value at any point during 2025, which may require reviewing monthly or quarterly statements.
- Convert foreign-currency values to US dollars. Use the US Treasury year-end exchange rate for the last day of the tax year. You may also use the rate shown on a financial account statement issued at least annually by the institution.
- Complete Form 8938. Part I summarizes deposit and custodial accounts. Part II summarizes other foreign assets. Parts V and VI provide detailed information for each account and asset.
- Attach Form 8938 to your tax return. File by your applicable deadline – April 15, 2026; June 15, 2026 for qualifying expats abroad; or October 15, 2026 with an extension.
- Check for related forms. If you also have FBAR, Form 3520, Form 3520-A, Form 5471, Form 8621, or Form 8865 obligations, file those separately. Identify the forms other than FBAR on Part IV of Form 8938.
Before you file – document checklist
Gather these records before you start completing the form:
- Foreign account statements showing maximum values during the year
- Ownership documentation for each account and asset
- Foreign entity registration documents, if applicable
- Exchange-rate records for each conversion
The current Form 8938 filing instructions are published as a continuous-use document and apply to all tax years until the IRS releases a revision.
What happens if I don’t file Form 8938?
A $10,000 penalty applies for failing to file a complete and correct Form 8938 by the due date, including extensions. This penalty applies even if you owe no tax on the underlying foreign assets.
If you still have not filed 90 days after the IRS mails a notice of failure, an additional $10,000 penalty applies for each 30-day period – or part of a period – of continued non-filing. The maximum additional penalty is $50,000, for a potential total of $60,000 per form, per year.
Other penalty exposure
The $10,000 initial penalty is not the only risk. Three additional consequences can apply:
- 40% accuracy-related penalty. If you underpay your tax because of a transaction involving an undisclosed specified foreign financial asset, the IRS may impose a 40% penalty on the underpayment.
- Criminal penalties. In cases involving willful non-compliance, criminal penalties may apply under the general tax fraud and tax evasion statutes.
- Extended statute of limitations. If you fail to file Form 8938, the statute of limitations for the tax year may remain open – in whole or in part – until three years after you file the form. A separate six-year statute applies when more than $5,000 of income from specified foreign financial assets is omitted.
What to do if you receive a notice
If the IRS sends a notice of failure to file Form 8938, take these steps immediately:
- Do not ignore the notice. The 90-day clock starts on the mailing date.
- Gather your foreign account statements and asset records.
- Consider professional advice before submitting corrective filings – the approach you take affects your penalty exposure.
For details on FATCA penalty amounts and how they interact with FBAR penalties, see our FATCA penalties guide.
What if I forgot to file Form 8938 in a previous year?
The right remedy depends on your full filing picture – not just the missed Form 8938. A missed Form 8938 often comes with missed FBARs, unreported foreign income, or other unfiled international information returns.
The compliance path you choose depends on your filing history, whether the failure was non-willful, and whether the IRS has already contacted you.
Key compliance paths
The IRS offers several formal programs depending on your circumstances:
- Streamlined Foreign Offshore Procedures. For eligible taxpayers living outside the US whose failure was non-willful. Covers three years of delinquent or amended returns and six years of FBARs. No Title 26 miscellaneous offshore penalty applies to qualifying SFOP submissions.
- Streamlined Domestic Offshore Procedures. For eligible US-resident taxpayers whose failure was non-willful. Requires previously filed returns to be amended. A 5% miscellaneous offshore penalty applies, calculated on the highest aggregate year-end balance of unreported foreign financial assets over the six-year FBAR period, as explained in our Streamlined Filing Compliance Procedures guide.
- IRS Voluntary Disclosure Practice. For cases involving willful conduct or where the taxpayer wants the protection of a formal voluntary disclosure.
Before you get help – gather these records
Having these documents ready will speed up any compliance review:
- Prior-year tax returns, whether filed or not
- Foreign account statements for the relevant years
- FBAR filing history
- Any IRS notices you have received
If the IRS has already opened an examination or investigation, Streamlined is generally no longer available.
Real expat scenarios where Form 8938 applies
The following Form 8938 example scenarios illustrate when the reporting obligation is triggered and when it is not. Each example uses hypothetical figures to show how the threshold analysis works – not to give individual legal conclusions.
Scenario 1 – employee with local bank accounts
A US citizen works in Germany, files as unmarried, and meets the bona fide residence test. She holds three foreign bank accounts with a combined maximum value of $250,000 during 2025. The year-end balance is $210,000.
Threshold analysis: The abroad threshold for an unmarried filer is more than $200,000 at year-end or more than $300,000 at any time. Her year-end balance exceeds $200,000, so she must file Form 8938.
Scenario 2 – married couple filing jointly
A US couple lives in France, both are bona fide residents, and they file a joint return. Their combined foreign accounts and investments total $450,000 at year-end, with a mid-year peak of $520,000.
Threshold analysis: The abroad threshold for married filing jointly is more than $400,000 at year-end or more than $600,000 at any time. The year-end balance exceeds $400,000, so they file Form 8938.
Scenario 3 – investor with foreign shares and a foreign fund
A US citizen in Singapore holds $180,000 in directly owned foreign stocks and $50,000 in a foreign mutual fund. He files as unmarried and meets the physical presence test. Year-end total: $230,000. Mid-year peak: $270,000.
Threshold analysis: The year-end total of $230,000 exceeds the more than $200,000 (2025) year-end threshold. The mid-year peak of $270,000 does not exceed the more than $300,000 (2025) any-time threshold. Because the year-end test is met, he must file Form 8938. The foreign mutual fund may also require Form 8621.
Scenario 4 – taxpayer who needs both Form 8938 and FBAR
A US resident holds a single foreign bank account with a maximum value of $85,000 during 2025. She files as unmarried and lives in the US.
Threshold analysis for Form 8938: The US-resident threshold for unmarried filers is more than $50,000 at year-end or more than $75,000 at any time. Her $85,000 peak exceeds $75,000 – she must file Form 8938.
Threshold analysis for FBAR: The FBAR threshold is $10,000 aggregate across all foreign financial accounts. Her $85,000 exceeds it – she must also file an FBAR.
A Form 8938 sample is available on the IRS Form 8938 page for reference before you begin completing the form.
How to convert foreign account values for Form 8938
The Form 8938 exchange rate method requires you to use a reasonable rate to convert each foreign-currency value to US dollars and retain documentation of the rate you applied.
Three-step conversion process
Convert each foreign-currency asset to US dollars before entering values on Form 8938:
- Identify the maximum value of each account or asset during the tax year. Review statements to find the highest balance. This is not the year-end balance – it is the peak value at any point in 2025.
- Select an exchange rate. The default is the US Treasury year-end exchange rate for December 31 of the tax year. You may also use the rate shown on a financial account statement issued at least annually by the institution holding the account.
- Retain your records. Keep copies of the statements showing the maximum value, the exchange rate you used, and the source of that rate.
Worked example
A US expat holds a UK savings account. The highest balance during 2025 was GBP 148,000. The US Treasury exchange rate for December 31, 2025, was approximately 0.74 GBP per USD.
Conversion: GBP 148,000 / 0.74 = $200,000.
This $200,000 is the maximum value reported for this account on Form 8938. For the any-time test, compare this maximum-value figure to the abroad threshold of more than $300,000 (2025) – not the year-end threshold.
Since $200,000 does not exceed $300,000, this account alone does not trigger filing under the any-time test. The year-end test uses a different number: the account’s actual balance on December 31, 2025. If that balance is also $200,000, the year-end test is not triggered either, because the threshold is “more than $200,000” (2025).
NOTE! Valuation rules differ by asset type. The rate on a financial account statement is acceptable for accounts; other assets – such as a direct interest in a foreign entity – may require a different approach. Retain all documentation.
The IRS accepts multiple exchange-rate sources for different forms – Treasury year-end rates for Form 8938 and FBAR, and IRS yearly average rates for income reported on Form 1040.
Where to find the Form 8938 PDF and instructions
The current Form 8938 and its instructions are continuous-use documents – they apply to all tax years until the IRS publishes a revision. Confirm you are using the most recent version before filing.
- Form 8938 PDF: Available on the IRS Form 8938 page
- Form 8938 instructions: Available on the IRS instructions page for Form 8938
The current revision is dated November 2021. The IRS updates both the form and instructions as needed without issuing annual revisions.
Form 8938 PDF preview
If you need to determine whether you are required to file, the IRS also publishes an eligibility guide for Form 8938.
Final thoughts
Form 8938 is one of the most commonly missed information returns among expats with foreign accounts.
Getting it right involves three steps: confirm whether you are required to file a US return, total your qualifying foreign assets, and compare the result against the correct threshold for your filing status and residency.
If the threshold is met, file Form 8938 with your return. If you also hold foreign financial accounts over $10,000 in aggregate, file an FBAR separately. The two forms overlap in coverage but are not interchangeable.
At Taxes for Expats, we have helped over 50,000 expats file accurately and avoid costly mistakes.
Our CPAs handle asset identification, currency conversion, and form preparation as part of every return – including FATCA reporting and FBAR filing.
FAQs on Form 8938 filing
Form 8938 is required when a specified individual has a US income tax return filing obligation, and the total value of specified foreign financial assets exceeds the applicable threshold. The form is attached to your federal return – it is not filed separately.
IRS Form 8938 is the FATCA reporting form that specified individuals attach to their federal tax return to disclose foreign financial assets above the applicable threshold. Its full name is Statement of Specified Foreign Financial Assets.
FATCA – the Foreign Account Tax Compliance Act – is the law behind Form 8938. The form itself is the individual reporting obligation that FATCA creates for specified individuals above the asset thresholds.
US citizens, resident aliens, and certain specified domestic entities must file if they have a return filing obligation and the Form 8938 reporting threshold for their filing status and residency is exceeded.
Any specified individual – US citizen, resident alien, or qualifying specified domestic entity – who is required to file a US income tax return and holds specified foreign financial assets above the applicable threshold.
The Form 8938 filing requirements apply for any tax year in which you meet all three conditions: specified-individual status, a return filing obligation, and foreign assets above the threshold. There is no minimum income trigger – the filing obligation alone is sufficient.
Form 8938 is due with your federal tax return – April 15, 2026, for the 2025 tax year, with extensions to June 15 or October 15, 2026, depending on your circumstances. The Form 8938 filing threshold is tested against the tax year, not the filing date.
The Form 8938 requirements apply if you are a specified individual required to file a US income tax return and the total value of your specified foreign financial assets exceeds the threshold for your filing status and residency.
No. Form 8938 must be attached to a federal income tax return such as Form 1040, 1040-NR, or 1040-SR. The IRS will not accept it as a standalone submission.
Yes. If you e-file your federal return, Form 8938 is included as an electronic attachment. The current IRS instructions for Form 8938 confirm that e-filing is accepted.
Exception: Streamlined Filing submissions that include Form 8938 must be mailed on paper.
Foreign financial accounts, foreign stocks and securities held directly, interests in foreign entities, foreign mutual funds, and certain foreign insurance or pension contracts. Directly held foreign real estate is not reportable, but an entity interest connected to foreign real estate may be.
Assets held at a US-based financial institution, assets at a foreign branch of a US financial institution, directly held foreign real estate, directly held foreign currency, and assets already reported on Forms 3520, 3520-A, 5471, 8621, or 8865 – these must still be identified on Part IV.
The statute of limitations for the tax year may remain open – in whole or in part – until three years after you file Form 8938. A separate six-year statute applies when more than $5,000 of income from specified foreign financial assets is omitted.
Yes. Form 8938 and FBAR are separate requirements with different thresholds, different asset scopes, and different filing destinations. Filing one does not satisfy the other.
The right remedy depends on whether you were non-willful, whether you have unfiled returns or FBARs beyond the missed Form 8938, and whether the IRS has contacted you. The Streamlined Filing Compliance Procedures are the most common path for non-willful expats abroad.
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