Thousands of American passport holders live in Hong Kong, where you may have local bank accounts, brokerage investments or retirement plans abroad. If at any point your overseas accounts total more than $10,000, you must file FinCEN Form 114 (FBAR) by April 15. A recent update set willful penalties at up to 50% of the account balance (as high as $165,353 per violation in 2025). Good news, mastering foreign account compliance is simpler than it sounds.

Here’s the key idea. Meeting your reporting rules on time keeps you in the IRS’s good graces so you can focus on life abroad.

Break down reporting rules

Overview of FATCA

Under the foreign account tax compliance act, you report specified foreign financial assets on Form 8938 once they exceed the FATCA reporting thresholds. For most expats, that means more than $200,000 at year-end or $300,000 at any point in the year (for those living outside the United States). You attach Form 8938 to your annual tax return. These FATCA reporting obligations apply in addition to any FBAR duty.

Overview of FBAR

You file FinCEN Form 114 (FBAR) if your combined foreign bank, brokerage or mutual fund accounts exceed $10,000 at any time during the calendar year. You submit it electronically through FinCEN’s BSA E-Filing system (see overseas bank account reporting). The foreign bank account reporting rules cover any financial interest or signature authority you hold, even if you don’t earn income from the account.

Track deadlines and extensions

FBAR due dates and extensions

You must file your FBAR by April 15 for the prior calendar year, with an automatic extension to October 15 (no need to request it). If you’re affected by a natural disaster, the IRS may grant further relief (check relevant FinCEN notices).

FATCA submission timeline

You file Form 8938 with your income tax return. U.S. expats get until June 15 to file, with an automatic extension to October 15 if needed (you can also request a further extension to April 15 of the next year). Plan ahead so you bundle your expat tax return with your FATCA disclosure (see foreign account disclosure requirements).

Fix missed filings

Delinquent FBAR submission

If you missed the FBAR deadline without willful intent, you can use the delinquent submission procedures. This lets you file past FBARs (and Form 8938, if needed) without penalty, as long as the IRS has not contacted you about your offshore accounts.

Streamlined compliance options

If you have unfiled reports for multiple years, consider the Streamlined Foreign Offshore Compliance Program. This program offers reduced penalties (or no penalty for nonwillful errors) once you certify your failure was unintentional. Weigh pros and cons carefully, and get advice before you apply.

Keep compliant year round

Organize your offshore assets

Make a list of all your foreign holdings: bank accounts, brokerage accounts, retirement plans and digital assets. Update it at year-end so you know if you cross any foreign asset reporting requirements or FATCA thresholds for the next filing season.

Partner with a tax professional

Handling foreign account compliance can feel overwhelming. At American Pacific Tax, we guide you through every form, deadline and program. If you need expert help with expat tax return preparation, reach out early so you avoid a last-minute rush.

Quick recap and next step

  1. Review your list of foreign assets.
  2. Confirm if you meet FBAR or FATCA thresholds.
  3. Mark your calendar for April 15 and June 15 deadlines.
  4. File on time or use delinquent procedures if needed.
  5. Check in with our team for a smooth filing.

You’ve got this, and once your filings are in order, you can focus on your adventures in Hong Kong.

FAQs

Do I need to file both FBAR and FATCA disclosures?
Yes, if you meet each form’s threshold you must file both. FBAR checks your total foreign account balances (over $10,000) while Form 8938 covers foreign financial assets over the FATCA thresholds. Review the specific fatca reporting thresholds to see which rules apply.

What happens if I miss a reporting deadline?
Missing a deadline can lead to penalties, but nonwillful missed FBAR reports can be cleared through delinquent submission procedures. For multiple missed years, the streamlined program may reduce or eliminate penalties. It’s best to act before the IRS reaches out.

Where can I find official IRS guidance on foreign account reporting?
Visit the IRS foreign account disclosure page for step-by-step instructions on filing Form 8938 and FBAR correctly.