Foreign assets over the threshold
U.S. taxpayers whose specified foreign financial assets exceed the reporting threshold must file Form 8938 with their return.
Form 8938 is the FATCA report for specified foreign financial assets, filed with your tax return. It overlaps with the FBAR but is a separate form with different thresholds — and missing it carries a $10,000 penalty that can climb to $50,000.
As an international tax specialist, I prepare Form 8938 alongside your FBAR and income tax return so the three agree and nothing keeps your return open longer than it should be.

U.S. taxpayers whose specified foreign financial assets exceed the reporting threshold must file Form 8938 with their return.
Expats have much higher thresholds — but many still cross them once foreign accounts, funds, and pensions are added up.
Form 8938 and the FBAR overlap but are separate filings with different thresholds. Many people owe both.
Foreign brokerage accounts, funds, partnership interests, and certain foreign pensions are all specified assets.
Form 8938 is filed with your return, so it has to line up with everything else on it. I make the two consistent.
Base penalty for not filing a complete, correct Form 8938 by the due date.
An additional $10,000 for each 30-day period after 90 days from IRS notice.
On understatements of tax tied to undisclosed foreign assets — double the standard 20%.
Leaving Form 8938 off your return can keep the whole return open to IRS assessment.
Form 8938 penalties stack quickly and the open statute is the quiet risk — an unfiled 8938 can keep an entire year auditable long after you thought it was closed.
They cover similar ground but are separate. The FBAR (FinCEN 114) is filed with FinCEN and reports foreign financial accounts over $10,000 combined. Form 8938 is filed with your tax return under FATCA, covers a broader set of specified foreign financial assets, and uses higher thresholds that depend on filing status and whether you live in the U.S. Many people must file both.
For taxpayers living in the U.S., the threshold is generally more than $50,000 in specified foreign assets on the last day of the year (or more than $75,000 at any point) for single filers, and double that for joint filers. For taxpayers living abroad the thresholds are much higher — generally $200,000 / $300,000 for single filers and $400,000 / $600,000 for joint filers.
Foreign bank and brokerage accounts, foreign stock or securities held outside an account, interests in foreign entities such as partnerships, foreign mutual funds, and certain foreign pensions and deferred compensation. U.S.-based accounts holding foreign investments generally do not count.
A $10,000 penalty for failing to file a complete and correct form by the due date, plus up to $50,000 more if the failure continues after the IRS sends notice. Understatements of tax tied to undisclosed assets can also carry a 40% accuracy penalty, and the omission can keep the statute of limitations on your return open.
Only if you cross the 8938 threshold that applies to you — but remember you also have to consider the FBAR, whose threshold is just $10,000 combined. It is common to owe the FBAR but not Form 8938, so both should be checked together. See my FBAR filing page.
Tajma Qorri is the founder of Qorri Tax Service LLC and an international tax specialist with more than 10 years in public accounting at Plante Moran, Grant Thornton, and Dean Dorton. Her focus is cross-border compliance — Forms 5471, 5472, 3520, and 8938; FBAR reporting; streamlined filing procedures; and tax-treaty analysis — for individuals and small businesses.
Every engagement is handled directly by Tajma, never passed to junior staff, and she has filed returns for clients in all 50 states. You get a firm, flat-fee quote before any work begins.

Qorri Tax works from an office at 222 S Prospect Ave in Park Ridge, IL, serving Chicago-area clients in person and clients in all 50 states remotely. Whether you are around the corner or across the country, Form 8938 preparation is handled the same way — directly by Tajma, start to finish.
FATCA / Form 8938 reporting starts at $150, quoted as a flat fee up front. See full pricing →
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