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FBAR & Form 8938 threshold checker

Two filings, different thresholds, different rules about what even counts. Add your foreign accounts once and see which — if either — is due.

Your foreign accounts and assets
● FBAR   ● 8938
● FBAR   ● 8938

Foreign pension treatment is contested in places — most preparers report super, PPF, EPF and NPS on both forms.

FBAR aggregate (peak)
$51,488
Over US$10,000 — FinCEN Form 114 due
8938 on 31 Dec
$45,923
Threshold $50,000
8938 highest
$51,488
Threshold $75,000

You are over the FBAR threshold. FinCEN Form 114 is filed online, separately from your tax return — due 15 April with an automatic extension to 15 October.

You are under both Form 8938 thresholds for this filing status.

Exchange rates used

Treasury Reporting Rates of Exchange for 2025-12-31 — the source FinCEN’s instructions name. Quoted as foreign currency per US$1.

Thresholds and arithmetic only. Whether you are a US person, whose accounts these are, and what you must file are questions for a preparer — this page does not answer them and is not tax advice.

enMoney tracks Indian and Australian accounts, funds, pensions and property in one ledger, priced daily and converted to whichever currency you think in. A US tax pack — Form 8949, Schedule D, foreign tax credit — is not built. Leave your email if that is the one you need. What enMoney does and doesn’t do for US filers.

The FBAR — FinCEN Form 114 — is not part of your tax return. It is due when the combined highest balances of your foreign financial accounts top US$10,000 at any point in the calendar year. That figure has not moved since 1970 and is not indexed, which is why a single overseas salary account can reach it.

The aggregation rule is where people go wrong. Each account contributes its own peak, and the peaks are added even if the money was never in two places at once. Move ₹700,000 from one account to another in June and that peak is reported twice — roughly US$15,600 in aggregate on about US$7,800 of actual money, and an FBAR is due. That is the rule working as written, not a quirk.

Form 8938 is filed with the 1040 and has far higher thresholds that depend on filing status and whether you live in the US: US$50,000 on 31 December or US$75,000 at any time for a single filer stateside, rising to US$200,000 / US$300,000 for someone living abroad, and doubling again for joint filers. It also covers more than accounts — foreign shares held directly on a register count here even though there is no account for the FBAR to attach to.

Directly-held foreign real estate is on neither form, which surprises people whose largest overseas asset is a flat. Shares in a company that owns property are a different matter, and the bank account collecting the rent certainly is reportable.

One thing worth knowing beyond the thresholds: if any of those accounts holds a non-US mutual fund or ETF — an Indian equity fund, an Australian managed fund — you are very likely holding a PFIC. That brings Form 8621 and a punitive default tax treatment, independent of whether either threshold above is met.

Conversion is at the US Treasury's Reporting Rates of Exchange for 31 December of the year being reported, which is the rate FinCEN's instructions specify. It is not your bank's rate and not the ECB's, and the difference is enough to move a borderline total across a threshold.

Other free calculators cover Indian and Australian capital gains, PPF and super.

Frequently asked questions

What is the FBAR threshold?

US$10,000. You file FinCEN Form 114 if the combined highest balances of all your foreign financial accounts exceeded US$10,000 at any point during the calendar year. The threshold is not indexed to inflation and has been unchanged since 1970.

Do I add up the highest balance of every account, even if I moved the same money between them?

Yes. Each account contributes its own maximum value during the year, and those maximums are summed. Transferring a balance from one foreign account to another means the same money is counted twice, which can put you over the threshold with no new money. That is how the form is written.

Is Australian superannuation reportable on the FBAR?

Most preparers report superannuation on both the FBAR and Form 8938 as a foreign financial account, and the same approach is usually taken for Indian PPF, EPF and NPS. The treatment of foreign pensions is contested in places, so confirm it with a preparer who handles your country.

Does foreign real estate count toward the FBAR?

Directly-held foreign property is not reportable on the FBAR or on Form 8938 — neither form covers real estate you own outright. Shares in a foreign company or trust that holds the property can be reportable, and a foreign bank account holding the rent certainly is.

What is the difference between the FBAR and Form 8938?

The FBAR is FinCEN Form 114, filed separately from your tax return, triggered at US$10,000 of aggregate account peaks. Form 8938 is filed with your 1040, has thresholds from US$50,000 to US$600,000 depending on filing status and whether you live abroad, and covers assets beyond accounts — such as foreign shares held directly. Many people have to file both, reporting the same accounts on each.

Which exchange rate do I use for the FBAR?

The US Treasury Reporting Rates of Exchange for 31 December of the year you are reporting. FinCEN’s instructions name that source specifically. This tool loads those published rates and lets you override any of them.

I hold Indian mutual funds. Is there anything else to worry about?

Probably yes. A non-US pooled fund held by a US person is almost always a PFIC, which brings Form 8621 and a default tax regime that is deliberately punitive. It is a separate obligation from the FBAR and Form 8938 and applies regardless of whether you cross either threshold.

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