Foreign Asset Reporting Thresholds — Do You Qualify?
FBAR · FATCA 신고 기준 금액 완전 해설 — 한국인 고위험 시나리오 포함

Threshold Summary — Side by Side FBAR · FATCA 기준 금액 비교

FBAR Threshold — How It Works FBAR 기준 금액 — 계산 방법

Three Rules That Together Define the FBAR Threshold

• Rule 1 — Aggregate across all accounts: The $10,000 threshold is applied to the sum of the peak balances across every foreign financial account combined — not to each account individually. Three accounts each peaking at $3,500 = $10,500 aggregate → FBAR required. Each individual account is below $10,000; the aggregate is not.
• Rule 2 — Peak balance, not year-end: Each account contributes its highest balance at any point during the calendar year — not its December 31 closing balance. An account that held $18,000 in March and ended at $2,000 in December contributes $18,000 to the FBAR aggregate calculation.
• Rule 3 — Even one day suffices: The $10,000 aggregate needs to be exceeded only at a single moment during the year. If the combined Korean account balances were $11,000 on March 15 and fell below $10,000 for the rest of the year, the FBAR is still required for that full calendar year.

FATCA Thresholds — 4 Categories FATCA 기준 금액 — 4가지 경우

The FATCA threshold depends on two factors: (1) filing status, and (2) whether you are a U.S. resident or living abroad. The "living abroad" exception applies to taxpayers who qualify as a bona fide resident of a foreign country or who were present outside the U.S. for at least 330 full days during a 12-month period — not simply anyone with a Korean address.

KRW Conversion — 2026 Practical Reference 2026 원화 → 달러 환산 기준

All Korean won balances must be converted to USD to compare against FBAR and FATCA thresholds. For FBAR, use the Treasury December 31 rate. For the FATCA "any time" threshold, use the rate on the date the maximum value occurred. The approximate rate below uses 1 USD = 1,370 KRW for illustrative purposes — always use the official Treasury rate for your specific year.

Peak Balance Rule — Not Year-End 최고잔액 기준 — 12월 31일 잔액 아님

Both FBAR and FATCA use maximum values — not December 31 closing values — to determine whether the threshold is exceeded. Understanding this distinction is critical for taxpayers whose Korean account balances fluctuate significantly during the year.

• For FBAR: Report the maximum aggregate value of all accounts combined at any single point during the year. If the aggregate peaked at $25,000 in June, report $25,000 — even if the December 31 aggregate is $3,000.
• For FATCA Form 8938: Two independent tests. Test 1: value on December 31. Test 2: maximum value at any time during the year. Either test independently triggers Form 8938. Report the higher of the two values on the form itself (though only one test needs to be exceeded to trigger the filing requirement).
• Why this matters for Korean accounts: Korean accounts often spike around specific events — receiving a Korean inheritance, selling Korean real estate, receiving 퇴직금 (severance), or making a large 적금 (installment savings) withdrawal. These temporary spikes — even if the money is immediately transferred elsewhere — create the FBAR and FATCA threshold analysis obligation for that year.

Joint Accounts — 100% Rule 공동 계좌 — 100% 신고 원칙

If a U.S. person has any financial interest in or signature authority over a foreign financial account — including accounts held jointly with a Korean parent, spouse, or business partner — the full account balance is reportable on the FBAR. The U.S. person does not report only their proportional share.

Residency Requirement 신고 의무 발생 조건 — 미국 거주자

FBAR and FATCA apply only to "U.S. persons" — a category defined by U.S. law, not by physical location. Non-resident aliens who file Form 1040-NR generally do not have FBAR or FATCA obligations.

Korean Scenario Matrix — 12 Situations 한국인 상황별 신고 의무 매트릭스

The following matrix covers the most common Korean account and asset combinations. All examples assume a single U.S. resident filer (not MFJ, not living abroad) for FATCA threshold comparison. Adjust thresholds for MFJ or abroad status as applicable.

6 Fully Computed Korean Examples 실제 사례 6개 — 계산 포함

Common Mistakes 자주 발생하는 오류

• 1 Applying the $10,000 threshold per account rather than in aggregate. The FBAR $10,000 threshold applies to the sum of all foreign accounts combined — not to each account individually. Three accounts at $4,000 each = $12,000 aggregate → FBAR required, even though no single account exceeds $10,000. This is one of the most common threshold misapplications.
• 2 Using the December 31 balance instead of the peak balance during the year. Both FBAR and FATCA require the highest value during the year — the December 31 closing balance is irrelevant to the threshold calculation except for FATCA's year-end test. An account that peaked at $60,000 in April and fell to $3,000 by December 31 reports $60,000 as the FBAR maximum balance, and the $60,000 peak is evaluated against FATCA's "any time" threshold.
• 3 Using the single/MFJ FATCA threshold when the higher abroad threshold applies. Green card holders and U.S. citizens living in Korea with 330+ days outside the U.S. qualify for the higher abroad FATCA thresholds ($200K/$300K for single, $400K/$600K for MFJ) — not the standard U.S. resident thresholds ($50K/$75K and $100K/$150K). Applying the lower resident threshold when the abroad threshold applies may cause unnecessary Form 8938 filings for Korean-based taxpayers.
• 4 Treating MFS as having the MFJ threshold for FATCA. Married Filing Separately (MFS) is NOT the same as Married Filing Jointly (MFJ) for FATCA thresholds. MFS filers use the single threshold ($50K/$75K for U.S. residents) — not the higher MFJ threshold ($100K/$150K). This is an easy error to make but can result in missing a Form 8938 filing obligation.
• 5 Not reporting the full balance of joint accounts with Korean parents. Being listed as a joint holder — even as a "convenience" arrangement with no actual access or control — creates a financial interest in the account requiring FBAR reporting of 100% of the balance. The full $80,000 of a joint account is reportable — not $40,000 (a 50% share). This rule catches many Korean-Americans who are listed on parents' accounts purely for administrative convenience.
• 6 Not recognizing that FBAR covers the full calendar year in a dual-status arrival year. In the year a person first becomes a U.S. tax resident, the FBAR covers the entire calendar year — including the pre-residency period from January 1. If Korean accounts exceeded $10,000 in February (before the July 1 residency start date), the FBAR is still required for that year. The FBAR threshold measurement is not limited to the post-residency period.
• 7 Thinking a temporary spike in Korean accounts doesn't matter if the money was quickly transferred. A temporary large deposit — inheritance, 퇴직금, real estate proceeds — that exceeds the threshold even for a single day triggers the full-year FBAR obligation and potentially FATCA. The money does not need to remain in the Korean account; the threshold analysis looks at the peak balance during the year, not the duration of that peak.
• 8 Assuming that filing FBAR satisfies FATCA or vice versa. FBAR and Form 8938 are entirely separate legal requirements enforced by separate agencies (FinCEN vs. IRS) under separate laws (Bank Secrecy Act vs. IRC). Filing one does not satisfy or replace the other. When both thresholds are met, both must be filed independently — and the same Korean account may appear on both forms with different information reported on each.

Hanmi CPA Insight