The short answer
It depends on how you hold the investments:
- Inside a foreign brokerage or custodial account: the account is what gets reported — on the FBAR (it is a foreign financial account) and, if you meet its threshold, on Form 8938. You do not separately list each stock in it.
- Foreign stock held directly, outside any account: it can be reportable on Form 8938, but it is not reported on the FBAR.
| What you have (per the IRS comparison) | FBAR | Form 8938 |
|---|---|---|
| Foreign stock or securities held in a financial account at a foreign financial institution | The account is reported; contents not separately reported | The account is reported; contents not separately reported |
| Foreign stock or securities not held in a financial account | Not reported | Reported (if Form 8938 requirements are met) |
A. Securities inside a foreign brokerage account
The FBAR regulation counts a securities account — an account with a person in the business of buying, selling, holding, or trading stock or other securities — as a financial account. So a brokerage account in Taiwan or Hong Kong counts toward your FBAR $10,000 aggregate like a bank account. Its maximum value is the greatest value of everything in the account (cash and securities) during the year, as a reasonable approximation. See maximum account value.
B. Foreign stock you hold directly
Some people hold shares of a foreign company directly — for example, registered in their own name with the company, not through a broker. The IRS comparison says this foreign stock is not an FBAR item, but it is a specified foreign financial asset for Form 8938, subject to the Form 8938 thresholds and the requirement that you file an income tax return.
Example
Hui, a U.S. resident filing as single and living in the U.S., has a Taiwan brokerage account whose maximum value in 2025 was $42,000 (shares plus cash), and she directly holds shares in a Taiwan family company worth $15,000 that are not in any account. For the FBAR, she reports the brokerage account (over $10,000), but not the directly held shares. For Form 8938, both items count, so her specified foreign financial assets reached $57,000. As a single filer living in the U.S., she must file Form 8938 if their total was more than $50,000 on the last day of the year or more than $75,000 at any time during the year — so she checks her year-end values. If required, the brokerage account is reported as an account and the directly held shares are reported as a separate asset.
Dividends and gains from foreign investments are taxable income for U.S. citizens and residents, reported on your tax return. Foreign mutual funds and similar pooled funds may be passive foreign investment companies (PFICs) with their own complex rules and Form 8621. This guide does not cover those rules; see Foreign mutual funds and ETFs: PFIC rules and Form 8621, and get professional help if you hold foreign funds.