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.

FBAR (FinCEN 114)Form 8938Form 8621 (PFIC)Form 1116Missed years
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Free estimate. No office visit needed. We work by email (info@cltny.com).

T
Takuya Yukimoto · IRS Enrolled AgentCLT NY INC. · Jersey City, NJ · English / Japanese
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
ThresholdCombined value of foreign financial accounts over $10,000 at any time during the yearTotal specified foreign financial assets over the amounts below
How to fileElectronically through FinCEN’s BSA E-Filing System, not with your tax returnAttached to your Form 1040
Due dateApril 15, with an automatic extension to October 15Same as your tax return, including extensions
Yen to dollarsConvert each amount at the year-end exchange rate

Form 8938 thresholds

Where you live and how you fileOn December 31At any time in the year
Living in the U.S., single or married filing separatelyover $50,000over $75,000
Living in the U.S., married filing jointlyover $100,000over $150,000
Living abroad, single or married filing separatelyover $200,000over $300,000
Living abroad, married filing jointlyover $400,000over $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.

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Bank accounts

Ordinary and time deposits, foreign-currency deposits, Japan Post Bank. Dormant accounts with small balances are included.

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Brokerage accounts, including NISA

Accounts at Japanese securities firms count, NISA included. Japanese mutual funds and ETFs may also need PFIC reporting (Form 8621).

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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.

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Joint accounts and signature authority

Joint accounts with your spouse, and family or company accounts you can sign on, are reportable too.

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Japanese public pension

Government social-security-type benefits (such as Kosei Nenkin and Kokumin Nenkin) are not reported on either form.

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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.

1

Maximum balance

Find the highest balance of each account during the year from your passbook or statements.

2

Convert to dollars

Convert each amount at the U.S. Treasury’s year-end exchange rate.

3

Add them up

If the total is over $10,000, you file the FBAR.

4

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.

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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.

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Form 8938 penalties

$10,000 for failing to file, plus $10,000 for each 30 days after an IRS notice, up to $60,000.

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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.

Employee with Japanese accounts (FBAR)

$800

Base $600 + FBAR $200.

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FBAR + Form 8938

$1,000

Base $600 + FBAR $200 + Form 8938 $200.

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+ two Japanese mutual funds (PFIC)

$1,400

Base $600 + FBAR $200 + Form 8938 $200 + PFIC $200 × 2.

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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.

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