If My Income Is Below the US Tax Filing Requirement, Do I Still Need to File FBAR or FATCA?

Yes. Even if your income is below the filing threshold for the 2025 tax year (for example, $13,850 for single filers), you may still be required to file FBAR or FATCA forms if your foreign financial accounts or assets exceed certain thresholds.

FBAR (Foreign Bank Account Report) – FinCEN Form 114

You must file the FBAR if:

• You are a US citizen or a Green Card holder, and
• You had $10,000 or more in aggregate value across all foreign financial accounts at any point during 2025

This requirement applies even if you do not need to file a federal tax return based on income. Non-compliance can result in steep penalties—even for unintentional oversights.

Learn more about FBAR filing for expats

FATCA (Foreign Account Tax Compliance Act) – IRS Form 8938

You must file Form 8938 under FATCA if your foreign financial assets exceed the following thresholds:

• Single filer living abroad:
  • $200,000 on the last day of the year, or
  • More than $300,000 at any point during the year
• Married filing jointly living abroad:
  • $400,000 on the last day of the year, or
  • More than $600,000 at any point during the year

Failure to file Form 8938 when required can result in a $10,000 penalty, with additional penalties if the non-filing continues after an IRS notice.

Explore FATCA reporting requirements for expats

Greenback offers standalone FBAR and FATCA filing services, even if you’re not filing a full US tax return. We’ll help ensure you’re fully compliant and avoid costly penalties.

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