U.S.–Germany Foreign Account Reporting
German Accounts: FBAR & Form 8938
U.S. persons with German bank, brokerage or other financial accounts may have separate FBAR and Form 8938 reporting obligations. The two regimes overlap, but they use different thresholds, forms and reporting concepts and should be reviewed independently each year.
Overview
FBAR and Form 8938 are related, but not the same filing
German accounts can appear on both filings, but the filing thresholds, account definitions and reporting mechanics differ. Filing one does not automatically satisfy the other.
A clean annual process starts by identifying all foreign financial accounts and assets, determining ownership or signature authority and documenting the maximum value for the relevant year.
German tax perspective
The German TaxRep counterpart focuses on German tax reporting of bank, investment and other financial assets held by U.S. taxpayers in Germany.
FBAR
FBAR focuses on foreign financial accounts and aggregate account values
Aggregate threshold
FBAR filing is based on the aggregate value of foreign financial accounts, not on whether each individual account exceeds the threshold by itself.
Maximum account value
Each reportable account generally requires the maximum value reached during the calendar year, converted to U.S. dollars for reporting.
Signature authority
FBAR can apply even where the U.S. person does not own the account but has reportable signature or other authority over it.
Form 8938
Form 8938 can cover foreign financial assets beyond bank accounts
Separate filing thresholds
Form 8938 uses its own thresholds, which can vary by filing status and whether the taxpayer lives in the United States or abroad.
Broader asset scope
Form 8938 can include specified foreign financial assets that are not necessarily treated the same way under FBAR.
Filed with Form 1040
Form 8938 is generally attached to the U.S. income-tax return, unlike FBAR, which is filed separately.
No one-for-one substitution
An account reported on FBAR may also need to be considered for Form 8938; reporting on one form does not replace the other.
German Account Types
Different account structures require different documentation
Checking and savings accounts
Standard German bank accounts are typically the simplest foreign accounts to identify and document.
Read FBAR guideGerman brokerage and custody accounts
Brokerage accounts can combine cash, securities and investment products and may create additional PFIC or income-tax reporting.
Read investment account guideJointly owned German accounts
Joint accounts should be reviewed based on the U.S. person's ownership and reporting rules rather than simply dividing the balance.
Read FBAR guideGerman assets on Form 8938
Specified foreign financial assets can extend beyond ordinary deposit accounts.
Read Form 8938 guideGerman funds inside brokerage accounts
Foreign fund holdings can create Form 8621 reporting in addition to account-level FBAR and Form 8938 obligations.
Read Form 8621 guideU.S. tax returns while living in Germany
FBAR and Form 8938 should be coordinated with Form 1040, foreign tax credits and other annual information returns.
Read annual filing guideAnnual Reporting Checklist
Keep account-level records before year-end data becomes difficult to reconstruct
Account list
Maintain a complete list of German bank, brokerage and other foreign financial accounts held during the year.
Maximum values
Record each account's highest annual value rather than relying only on the December 31 balance.
Joint ownership
Document all owners and the U.S. person's ownership or authority over each joint account.
Account type
Distinguish deposit accounts, brokerage/custody accounts and accounts held for business or entity purposes.
Exchange rates
Use consistent U.S.-dollar conversion support for maximum balances and year-end reporting.
Supporting statements
Retain annual bank and brokerage statements so reported balances can be substantiated later.
Related U.S.–Germany Guides
Continue with the relevant reporting obligations
Tax Returns & Reporting
Return to the complete U.S.–Germany reporting hub.
Explore reportingFBAR for Americans in Germany
Foreign bank and financial account reporting.
Explore FBARForm 8938
FATCA reporting for German financial assets.
Explore Form 8938German Investment Accounts
Brokerage accounts, PFICs and related U.S. reporting.
Explore investmentsU.S.–Germany Foreign Account Reporting
Have German bank or brokerage accounts?
We can coordinate FBAR, Form 8938, joint-account reporting, brokerage accounts, exchange-rate documentation and related U.S. tax filings.
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