The preparation record
- Taxpayer residence and filing status for the year.
- Asset ownership, including joint, beneficial, or entity-held interests.
- Maximum values and the exchange-rate method used.
- Income, gains, losses, deductions, or credits connected to the assets.
- Related forms and where the same asset or income appears elsewhere on the return.
Assets are not limited to bank accounts
Potentially reportable assets can include foreign financial accounts, stock or securities held outside a financial account, interests in foreign entities, and certain foreign pensions, trusts, or contracts. The exact treatment depends on the form instructions and the taxpayer’s facts.
Directly held foreign real estate is generally not itself a specified foreign financial asset. An interest in a foreign entity that owns real estate can be a different analysis.
Thresholds need context
The reporting thresholds differ for joint and non-joint returns and can be higher for qualifying taxpayers living abroad. Values at year end and at any time during the year are both relevant. The filing-requirements guide provides the current framework, but it is not a substitute for applying the instructions to the facts.
Filing an FBAR does not automatically replace Form 8938. A taxpayer may need one, both, or neither.