FBAR · Form 8938
FBAR and Form 8938
for Japanese bank accounts.
If you are a U.S. person (citizen, green card holder, or an expat who meets the Substantial Presence Test) and the combined balance of your accounts in Japan went over $10,000 at any time during the year, you must file an FBAR (FinCEN Form 114). Larger amounts also require Form 8938 with your tax return. Our IRS Enrolled Agent reads your Japanese statements, finds each account’s maximum balance, converts yen to dollars and files everything, in English or Japanese.
Free estimate. No office visit needed. We work by email (info@cltny.com).
Do I Need to File?
FBAR vs Form 8938: who has to file
Both apply to U.S. persons. They are separate requirements, so you may need both.
| FBAR (FinCEN Form 114) | Form 8938 | |
|---|---|---|
| Threshold | Combined value of foreign financial accounts over $10,000 at any time during the year | Total specified foreign financial assets over the amounts below |
| How to file | Electronically through FinCEN’s BSA E-Filing System, not with your tax return | Attached to your Form 1040 |
| Due date | April 15, with an automatic extension to October 15 | Same as your tax return, including extensions |
| Yen to dollars | Convert each amount at the year-end exchange rate | |
Form 8938 thresholds
| Where you live and how you file | On December 31 | At any time in the year |
|---|---|---|
| Living in the U.S., single or married filing separately | over $50,000 | over $75,000 |
| Living in the U.S., married filing jointly | over $100,000 | over $150,000 |
| Living abroad, single or married filing separately | over $200,000 | over $300,000 |
| Living abroad, married filing jointly | over $400,000 | over $600,000 |
Exceeding either column means you file Form 8938. “Living abroad” means a bona fide resident of another country for the whole year, or physically present abroad at least 330 days in a 12-month period.
What Counts
Which Japanese accounts count
The test uses the combined total. Once you are over the threshold, you report every account, including small ones.
Bank accounts
Ordinary and time deposits, foreign-currency deposits, Japan Post Bank. Dormant accounts with small balances are included.
Brokerage accounts, including NISA
Accounts at Japanese securities firms count, NISA included. Japanese mutual funds and ETFs may also need PFIC reporting (Form 8621).
Insurance with a cash value
Japanese whole life, endowment and annuity policies with a surrender value are reported on both the FBAR and Form 8938.
Joint accounts and signature authority
Joint accounts with your spouse, and family or company accounts you can sign on, are reportable too.
Japanese public pension
Government social-security-type benefits (such as Kosei Nenkin and Kokumin Nenkin) are not reported on either form.
Will the IRS find out?
How information about Japanese accounts reaches the IRS, and why filing late on your own is better.
Read the article →How to Count
How to count balances and convert yen
Use each account’s highest balance during the year, not the year-end balance.
Maximum balance
Find the highest balance of each account during the year from your passbook or statements.
Convert to dollars
Convert each amount at the U.S. Treasury’s year-end exchange rate.
Add them up
If the total is over $10,000, you file the FBAR.
Report every account
List all accounts, including the small ones.
For example, at a year-end rate of ¥150 per dollar, a combined maximum of more than ¥1.5 million triggers the FBAR. Interest from Japanese accounts is U.S. taxable income even when small; Japanese tax withheld on it can be claimed as a foreign tax credit.
Missed Years
If you missed FBARs in past years
Coming forward before the IRS contacts you puts you in a much better position.
FBAR penalties
A non-willful failure can cost up to $16,536 per report (penalties assessed on or after January 17, 2025, adjusted for inflation each year). Willful violations: the greater of $165,353 or 50% of the balance. In 2023 the Supreme Court held that non-willful penalties apply per report, not per account.
Form 8938 penalties
$10,000 for failing to file, plus $10,000 for each 30 days after an IRS notice, up to $60,000.
Ways to catch up
The Delinquent FBAR Submission Procedures (when no income was left off your returns) and the Streamlined procedures (for non-willful omissions).
Read about Streamlined →Fees
Fee examples
The base fee is $600, plus the items you need. On the application page, pick the rough balance of your accounts outside the U.S. and the total, including whether you need the FBAR and Form 8938, appears right away. See all items on the fee list.
+ two Japanese mutual funds (PFIC)
$1,400
Base $600 + FBAR $200 + Form 8938 $200 + PFIC $200 × 2.
Frequently asked questions
Q. My Japanese balances are small. Do I still need an FBAR?Add up the highest balance of every account. If the total went over $10,000 at any time in the year, you file. If not, no FBAR is needed, but interest from those accounts is still reported on your U.S. return.Q. When is the FBAR due?April 15, with an automatic extension to October 15. It is filed electronically with FinCEN, separately from your tax return.Q. How are joint accounts with my spouse reported?Each owner of a joint account must report it. If all of your spouse’s reportable accounts are jointly owned with you and the other conditions are met, you can file one FBAR together using Form 114a.Q. Do I need both the FBAR and Form 8938?Often, yes. The FBAR goes to FinCEN and Form 8938 goes to the IRS with your return, and the thresholds are different. Anyone over the Form 8938 threshold usually needs the FBAR too.Q. I missed FBARs in past years. What should I do?Come forward before the IRS contacts you. Which procedure fits depends on whether any income was left off your returns, so we review your past returns and balances together first.Q. How much does it cost?The base fee is $600, plus $200 for the FBAR and $200 for Form 8938 if needed. Answer a few questions on the application page to see your fee right away.Free Estimate
See your fee, Japanese accounts included
An IRS Enrolled Agent handles your return in English or Japanese. Pick your rough balances and see right away whether you need the FBAR and Form 8938.
Get your quote → Contact us