Comparison
FBAR vs Form 8938
FBAR and Form 8938 are two separate US foreign-asset reports. The FBAR reports foreign financial accounts to FinCEN; Form 8938 reports specified foreign financial assets to the IRS with your tax return. They overlap, but filing one does not satisfy the other, and many Americans in the UK must file both.
The short answer
Two reports, two agencies, one taxpayer
| FBAR (FinCEN 114) | Form 8938 | ||
|---|---|---|---|
| Filed with | FinCEN (Treasury) | IRS (with Form 1040) | |
| What it reports | Foreign financial accounts | Specified foreign financial assets | |
| Filed separately from tax return | |||
| Covers non-account assets | |||
| Common for Americans in the UK |
- Filed with
- FinCEN (Treasury)
- What it reports
- Foreign financial accounts
- Filed separately from tax return
- Covers non-account assets
- Common for Americans in the UK
FBAR (FinCEN 114)
- Filed with
- IRS (with Form 1040)
- What it reports
- Specified foreign financial assets
- Filed separately from tax return
- Covers non-account assets
- Common for Americans in the UK
Form 8938
- Filed with
- What it reports
- Filed separately from tax return
- Covers non-account assets
- Common for Americans in the UK
How the two reports differ in practice
The FBAR is an information report sent to FinCEN about foreign accounts — think current accounts, savings, and certain pooled or pension-style arrangements. Form 8938 is broader in the types of asset it captures (it can reach beyond accounts to certain other financial assets), and it travels with your Form 1040 to the IRS.
Because the two use different definitions and are read by different agencies, the same account can appear on both, on one, or on neither, depending on your circumstances. That is why we assess each obligation independently rather than assuming one covers the other.
You may need to look at both if you
- Are a US person living in the UK with UK bank, savings or investment accounts
- Hold UK financial assets alongside everyday accounts
- Have previously filed only one of the two reports
- Are catching up through Streamlined Filing or the Delinquent FBAR procedures
At a glance
- FBAR filed with
- FinCEN (Treasury), via BSA E-Filing
- Form 8938 filed with
- IRS, attached to Form 1040
- Relationship
- Independent — one does not satisfy the other
- Typical UK situation
- Both often apply
Frequently asked questions
Often, yes. They are separate reports filed with different agencies. Many Americans in the UK meet the trigger for both, so filing one does not remove the obligation to file the other when its own conditions are met.
The FBAR (FinCEN Form 114) reports foreign financial accounts to the Treasury. Form 8938 reports specified foreign financial assets to the IRS with your tax return. They overlap but cover different assets and are filed separately.
The FBAR is filed electronically with FinCEN through the BSA E-Filing system. Form 8938 is attached to your Form 1040 and filed with the IRS.
No. The two obligations are independent. Reporting an account on the FBAR does not remove the requirement to also report it on Form 8938 if the Form 8938 conditions apply, and vice versa.
Not sure which reports apply to you?
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