FBAR & FATCA Foreign Asset Tracker

For FBAR, Treasury's Bureau of the Fiscal Service rate for the last day of the calendar year is generally used. For Form 8938, the IRS generally requires the U.S. Treasury Bureau of the Fiscal Service exchange rate for purchasing U.S. dollars when available; if no Treasury rate is available, another publicly available exchange rate may be used and disclosed as required. For Form 8938, the applicable exchange rate is generally the rate on the last day of the tax year.

A U.S. person with a financial interest in, or applicable signature or other authority over, a foreign financial account may have an FBAR reporting obligation. The account's maximum value is reported under the FBAR rules; do not assume that every joint account with a non-U.S. spouse is automatically treated the same way. Specific joint-account, spouse, ownership, and signature-authority rules and exceptions should be checked.

The answer depends on the asset and how it is held. A financial account maintained by a foreign financial institution can be reportable on both FBAR and Form 8938. Foreign stocks or securities held inside a reportable foreign financial account generally do not need to be separately reported on Form 8938 because the account itself is reported. Foreign stocks or securities held outside a financial account can be Form 8938 assets but are generally not FBAR accounts. Foreign mutual funds can be reportable under both regimes, and certain foreign mutual funds may also raise separate PFIC/Form 8621 issues.

The FBAR is due April 15 following the calendar year being reported, with an automatic six-month extension to October 15. Form 8938 is attached to the applicable federal income-tax return and is due with that return, including applicable extensions. The exact income-tax return deadline can vary by taxpayer and circumstance, so Form 8938 should not be described as independently due on April 15 in every case.

A foreign-issued life insurance or annuity contract with a cash-surrender value can be a specified foreign financial asset for Form 8938 and can also be a reportable foreign financial account for FBAR purposes when the applicable requirements are met. The two forms have different reporting rules, and the asset should not be described as simply belonging to Form 8938 Part I.

No. The higher Form 8938 thresholds apply only if you qualify as a taxpayer living abroad under the IRS rules. Generally, this requires a foreign tax home plus either bona fide residence in a foreign country or countries for an uninterrupted period that includes the entire tax year, or physical presence in foreign countries for at least 330 full days during a qualifying 12-month period.

Because the FBAR and Form 8938 tests use different threshold concepts. FBAR uses the aggregate maximum values of qualifying foreign financial accounts during the calendar year. Form 8938 has both an end-of-tax-year threshold and an any-time threshold, and its specified foreign financial asset category is broader than FBAR.

Yes. Depending on the circumstances, specified foreign financial assets can include foreign financial accounts plus certain foreign stocks or securities held outside a financial account, interests in foreign entities, certain foreign financial instruments or contracts, foreign pensions or deferred compensation plans, and certain foreign-issued insurance or annuity contracts with cash value.

No. The built-in rates are illustrative estimates and should not be represented as official 2026 Treasury rates. The applicable year-end Treasury Bureau of the Fiscal Service rate should be used for an actual filing calculation. A future year-end rate cannot be known before the relevant year ends.