U.S. taxpayers living abroad may be required to report their foreign financial accounts through two different reporting systems: FinCEN Form 114 (FBAR) and Form 8938 (FATCA). Although both reports involve foreign financial accounts, they are separate requirements, filed with different agencies, and follow different pricing and procedures when prepared through TFX.
This article explains when these reports are required, how they are filed through your TFX account, and how the related service fees are calculated.
FinCEN Form 114 (FBAR) filing cost
The FBAR filing fee is a flat $85, regardless of the number of financial accounts reported, when you enter your foreign financial account information directly in the Non-U.S. Financial Accounts section of the tax questionnaire (TQ) and submit the FBAR electronically to FinCEN directly from your TFX account. Detailed step-by-step instructions for this process are available in the guide: FBAR filing service: Request, manage, and e-file.
Because the FBAR can now be generated and filed directly through your TFX account, it is treated as a self-service add-on and not included in the Engagement Letter.
Exceptions:
If you file under the Streamlined Filing Compliance Procedures, FBAR reports for the previous six years will be handled by your assigned tax preparer. You don't need to file six FBARs manually through the Compliance monitor section. The cost of these FBAR filings is already included in the flat fee for the Streamlined Procedures service.
If you have foreign financial accounts with zero balances or provide account information through an Excel file or spreadsheet, the FBAR report will be handled by your assigned tax preparer. In these cases, the FBAR will be included in your Engagement Letter, and a different pricing structure will apply. The cost will be $85 for up to five accounts, plus $10 for each additional account. This pricing applies when the information cannot be entered directly through the questionnaire or requires manual processing by our team.
Form 8938 (FATCA) reporting cost
If you are required to file Form 8938 under FATCA, the reporting fee is $100 for up to five accounts, plus $10 for each additional account. This FATCA pricing structure applies regardless of how the account information is provided. Whether you enter the information directly into the Non-U.S. Financial Accounts section of the tax questionnaire (TQ) or upload a spreadsheet, the same FATCA reporting fee applies.
Unlike FBAR reporting, Form 8938 is part of your federal tax return (Form 1040) and must be prepared by your tax preparer. For this reason, the FATCA reporting fee is always included in your Engagement Letter.
Reporting more than 25 foreign financial accounts
Special reporting rules apply when taxpayers hold a large number of foreign accounts.
If you are required to file only an FBAR, and you have more than 25 foreign financial accounts, you are not required to list every account individually in the Non-U.S. Financial Accounts section of the tax questionnaire (TQ). The U.S. Treasury allows the FBAR to include a statement indicating that the taxpayer holds more than 25 foreign financial accounts, rather than listing each one.
However, the rule changes if you are required to file both FBAR and FATCA (Form 8938). In that case, all foreign financial accounts and assets must be reported individually on Form 8938, even if the total number exceeds 25. Because FATCA reporting requires detailed disclosure, you may provide a spreadsheet listing your accounts for our team to process if entering the information manually in the questionnaire is impractical and overwhelming.