US Tax

FBAR, FATCA, and FEIE: What US Expats Actually Have to File

By Michael Ashmore  ·  13 Aug 2026  ·  8 min read
Tax withholding forms, a calculator, and coffee on a dark desk
Three different forms, three different agencies, three different thresholds. Photo: Kelly Sikkema / Unsplash

About the author: Michael Ashmore is a British expat in the US who built RetireFlexi after discovering that no retirement calculator could handle pensions in two countries at once. He writes about the financial side of expat retirement that most guides skip.

FBAR is a Treasury filing, not a tax form, and it kicks in at $10,000. FATCA is an IRS filing, attached to your tax return, and kicks in much higher — $200,000 to $600,000 depending on filing status and timing. FEIE isn't a reporting requirement at all; it's an election that can shelter up to $132,900 of earned income from US tax in 2026. Three different things, constantly lumped together, and a lot of expats file one and assume it covers the others.

FBAR — the one that catches people off guard

The Report of Foreign Bank and Financial Accounts, filed as FinCEN Form 114, isn't optional once you cross the line: $10,000 aggregated across every foreign account you have signature authority over — checking, savings, a SIPP, a joint account you can access but don't own outright — at any single point during the year, not just December 31st. A UK current account that briefly held $8,000 plus a savings account with $3,000 on the same day crosses the threshold, even if neither account alone comes close.

It goes to FinCEN, a bureau of the Treasury Department — not the IRS, and not part of your tax return. Deadline is April 15, with an automatic extension to October 15 that requires no paperwork to claim.

Penalties are real. Non-willful failure to file can run up to roughly $13,600 per violation. Willful failure is the greater of about $136,000 or 50% of the account balance at the time of the violation — per account, per year. If you've missed past filings unintentionally, the IRS Streamlined Filing Compliance Procedure exists specifically to let you catch up without the willful-violation penalty structure.

FATCA — higher threshold, still a real requirement

The Foreign Account Tax Compliance Act requires Form 8938, filed with your regular Form 1040, once your foreign financial assets exceed a threshold that depends on filing status and whether you qualify as living abroad. For expats who qualify, the numbers are $200,000 single or $400,000 married filing jointly at year-end — or $300,000 / $600,000 if the value was higher at any point during the year. These thresholds are meaningfully higher than the ones that apply to people still living in the US.

FBAR and FATCA overlap in what they cover but aren't the same filing. Plenty of expats owe both — a mid-six-figure portfolio spread across a few foreign accounts routinely crosses both thresholds — and filing one doesn't excuse you from the other.

FEIE — the one that actually reduces tax

The Foreign Earned Income Exclusion, claimed on Form 2555, is different in kind from the two above: it's not a reporting requirement, it's an election that shelters income from tax. For 2026, up to $132,900 of foreign earned income per qualifying person is excludable. Qualify through either the bona fide residence test (a full tax year as a genuine resident of a foreign country) or the physical presence test (330 full days abroad in a 12-month period).

The catch that trips people up: FEIE only applies to earned income — wages, salary, self-employment income. It does nothing for pensions, Social Security, or investment returns, which is exactly the income most retirees are living on. A working expat and a retired expat have very different relationships to this exclusion.

How the three actually interact

FBAR FATCA FEIE
What it is Account reporting Asset reporting Income exclusion
Form FinCEN 114 Form 8938 Form 2555
Filed with FinCEN directly Form 1040 Form 1040
2026 threshold $10,000 (any point in year) $200k / $400k (living abroad) N/A — election, not a threshold
Reduces tax owed? No — reporting only No — reporting only Yes, up to $132,900 of earned income

For retirees specifically, FEIE usually matters less than the Foreign Tax Credit, since pension and Social Security income isn't earned income to begin with. The broader mechanics of double-taxation relief for retirement income are covered in the expat retirement planning guide.

Model the income these filings are based on

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Not financial or tax advice. This article describes filing requirements in general terms and does not prepare or file FBAR, FATCA, or any tax return. Thresholds and penalty amounts are adjusted periodically — verify current figures at irs.gov and fincen.gov, and consult a qualified expat tax preparer for your specific situation.