The short answer
Possibly — and the year you arrive needs extra care. Moving to the U.S. does not by itself create a reporting duty. What creates it is becoming a U.S. person (for the FBAR) or a specified individual (for Form 8938) and meeting each form's threshold. Your accounts' income is a separate, third question.
Work through four questions in order:
| Question | Why it matters |
|---|---|
| A. When did you become a U.S. resident for tax purposes? | Reporting obligations depend on your status, and the arrival year can be partial |
| B. Which reporting period applies? | FBAR and Form 8938 are separate regimes; do not assume their period rules are identical |
| C. Are the thresholds met? | FBAR: aggregate over $10,000 at any time. Form 8938: much higher thresholds that depend on filing status |
| D. Did the accounts earn income while you were a resident? | Interest and other income are reported on your tax return, separately from FBAR and Form 8938 |
A. When does U.S. residency start?
If you are not a U.S. citizen, you are generally a resident for tax purposes if you meet the green card test or the substantial presence test. In the year you arrive, the tax law has a residency starting date — for example, under the substantial presence test it is generally the first day you are present in the U.S. that year (with limited exceptions). See Am I a U.S. tax resident? and the substantial presence test guide.
B. Form 8938 and FBAR use different rules — check each one
Form 8938: the reporting period starts on your residency starting date
The Form 8938 instructions say that if you are a specified individual for only part of the tax year, the reporting period is the part of the year you are a specified individual. Their example: George, who is not a U.S. citizen, arrives in the U.S. on February 1 and meets the substantial presence test for the year. His Form 8938 reporting period begins on his residency starting date, February 1, and ends on December 31.
FBAR: a calendar-year report for U.S. persons
The FBAR is filed for each calendar year in which a U.S. person had a financial interest in or signature authority over foreign financial accounts whose aggregate value exceeded $10,000 at any time during the calendar year. For FBAR purposes, residency is determined under the tax law's residency tests — but IRS guidance notes that elections (such as treating a nonresident spouse as a resident) and tax treaty provisions do not change FBAR residency.
The official guidance reviewed for this guide does not spell out how account values from before your residency starting date are treated on the FBAR for your arrival year. Don't assume the Form 8938 rule carries over, and don't assume pre-arrival balances can simply be ignored. If your arrival-year balances were near or above $10,000, have that year reviewed by a tax professional.
C. Thresholds
- FBAR: the aggregate maximum value of your foreign financial accounts exceeded $10,000 at any time. See How the $10,000 rule really works.
- Form 8938: for taxpayers living in the U.S., more than $50,000 on the last day of the year or more than $75,000 at any time (unmarried); more than $100,000 or $150,000 (married filing jointly). Higher thresholds apply if you live abroad. Form 8938 is required only if you must file an income tax return. See FBAR vs. Form 8938.
D. Income from the accounts
As a U.S. resident you are taxed on worldwide income, so interest earned on foreign accounts while you are a resident is reported on your tax return. In your arrival year, the income tax return may be a dual-status return, which has its own rules. See Dual-status tax returns. Money you earned and saved before you came is not taxed again just because you move it — see I had this money before moving to America.
Example
Lin moves from Taipei to Seattle on a green card in August 2025 and keeps two Taiwan accounts. She works through the four questions: (A) she pins down her residency starting date for 2025; (B) for Form 8938, her reporting period starts on that date; (C) her accounts total far less than the Form 8938 threshold, but more than $10,000, so the FBAR is the live question — and because it is her arrival year, she has it reviewed; (D) she reports the Taiwan interest earned while she was a resident on her 2025 return.
Records to start keeping now
- Your arrival date and immigration documents (to establish your residency starting date)
- Monthly statements for every foreign account, from January of your arrival year
- Interest statements from foreign banks
- Year-end Treasury exchange rates for the currencies you hold