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Do you still have to file? A short answer for Americans abroad

  • Writer: Paratus Wealth US Team
    Paratus Wealth US Team
  • Aug 4
  • 3 min read


Most Americans who move abroad find out the same thing, usually later than they would like: leaving the United States does not end your filing relationship with the IRS.

The United States taxes on citizenship, not residence (IRS, International Taxpayers). So if you are a US citizen or a green card holder, the obligation follows you. It follows you to Dubai, to Lisbon, to Singapore. And it applies whether or not you owe a single dollar in tax, because reporting and paying are two separate questions. Plenty of Americans abroad owe nothing and are still required to file.

Two requirements catch people most often.

The FBAR is a report of your foreign bank and financial accounts. It is generally required when the combined high balance across all your foreign accounts passes ten thousand dollars at any point in the year (IRS, FBAR). Combined, not per account, which is why people who feel far below the threshold sometimes are not. A small number of accounts are excepted, so the detail is worth checking. It is filed with FinCEN, separately from your tax return.

Form 8938 is the FATCA reporting form. It goes in with your tax return, and its thresholds are considerably higher if you live abroad (IRS, Comparison of Form 8938 and FBAR). Many Americans overseas file both. Some file only one. The two have different rules, different thresholds and different filing routes, and being caught by one tells you nothing about the other.

If you have never filed, that is a more common position than most people assume, and a structured route back exists. The IRS Streamlined Foreign Offshore Procedures are open to non-residents whose failure to file was non-willful, and the IRS applies no penalties to those who qualify (IRS, US Taxpayers Residing Outside the United States). Non-willfulness is not something you can self-assess, and eligibility is rarely obvious from the outside. Both are a legal judgement, and one for a qualified US tax professional to reach rather than an article or an online tool. The certification involved is signed under penalty of perjury.

We have written the whole picture up properly: the thresholds, the side-by-side of FBAR against Form 8938, the traps that catch Americans abroad, and what the streamlined route actually involves.

The Paratus Wealth US team works with Americans living outside the United States on exactly this kind of cross-border picture. We help you understand the landscape and connect you with the right US tax professional when a filing question needs a specialist’s judgement; we do not prepare or file your returns. If you would like to talk it through, contact the US team.

Paratus Wealth US team members act as investment adviser representatives of Beacon Global Advisor Network, LLC (BGAN), an investment adviser registered with the US Securities and Exchange Commission. Paratus Wealth is not itself registered with the SEC as an investment adviser. Review BGAN’s relationship summary (Form CRS) and learn more at Investor.gov/CRS. This article is information and general education only. It is not tax, legal or investment advice, and it does not establish any advisory relationship. Reporting duties, thresholds and penalties depend on individual circumstances and change over time; a qualified US tax professional should assess any specific situation. Paratus Wealth does not provide services to, and does not market to, residents of the United Kingdom.

Disclaimer: Some of the content of this communication was provided by third parties of Paratus. We have not verified the information contained herein, but we believe the content is reliable. None of this content should be construed as legal, accounting or tax advice. Tax laws are complex and often have highly-individualized requirements, you should seek the advice of a competent tax professional if you have specific tax questions.

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​​The information provided on this website is intended exclusively for individuals located outside the United Kingdom and must not be used or relied upon by persons within the United Kingdom. This website is for informational purposes only and does not constitute, nor should it be relied upon as, financial, tax, legal, or accounting advice. You should consult a regulated financial adviser to assess your personal circumstances and obtain advice tailored to your individual situation. If any content on this website may have tax, legal, or accounting implications, you are strongly encouraged to seek guidance from independent professional advisers in those areas. When considering financial investments, please note that past performance is not indicative of future results, and the value of investments may fluctuate, resulting in potential losses as well as gains. For pensions, you should regularly review your pension arrangements to ensure they remain aligned with your objectives. The benefits you ultimately receive will depend on future investment performance. Paratus Wealth, its officers, and employees do not and cannot provide tax, accounting or legal advice.​ Specific advice should be sought from a relevant professional legal or tax adviser in your country of residence.

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