FinCEN 114 & IRS Form 8938 · Updated September 2026

Your Israeli bank account has two separate US filings.

Almost every American who owns property in Israel has an Israeli account behind it — for rent, for arnona, for the vaad bayit. That account triggers reporting under two different regimes, run by two different agencies, with two different thresholds. Filing one does not cover the other.

FBAR — FinCEN Form 114

The FBAR is filed with the Financial Crimes Enforcement Network, not with the IRS and not with your tax return. It goes in electronically through the BSA E-Filing system, separately from everything else you file.

The trigger is a US person having a financial interest in, or signature authority over, foreign financial accounts whose aggregate value exceeds $10,000 at any point during the calendar year. Three details in that sentence do most of the damage:

The deadline follows the tax return date in April, with an automatic extension to October that you do not have to request. There is no tax attached to the FBAR. It is purely an information return — which is precisely why people ignore it, and precisely why the penalties exist.

Form 8938 — a different form for a different agency

Form 8938 is filed with your income tax return, under the FATCA rules, and covers "specified foreign financial assets". It overlaps heavily with the FBAR without replacing it: the same Israeli account very often appears on both.

The thresholds are much higher than the FBAR's, and — importantly for this audience — they are higher again if you live abroad:

Living in the United States. Single: assets over $50,000 on the last day of the year, or over $75,000 at any time. Married filing jointly: $100,000 / $150,000.

Living abroad. Single: $200,000 / $300,000. Married filing jointly: $400,000 / $600,000.

So an American in Tel Aviv with a modest Israeli account may well have an FBAR obligation and no Form 8938 obligation. The reverse — 8938 without FBAR — is rare but possible.

What is not reportable, and why it matters

The apartment is not a financial asset. Real estate held directly in your own name is not reported on Form 8938, and it is not an account for FBAR purposes either. Many owners over-report out of caution, which is not free — it puts information on record that then has to be consistent every subsequent year.

But the exclusion is narrower than it sounds. It covers property held directly. Hold the same apartment through an Israeli company or another entity and you are no longer holding real estate — you are holding an interest in a foreign entity, which is a different and considerably heavier reporting question. If your property is not in your personal name, treat that as a specific matter to raise with an adviser.

This is not an inference from silence. The IRS publishes a line-by-line comparison of the two forms, and the row for "Foreign real estate held directly" reads No in both columns — not reportable on Form 8938, not reportable on the FBAR. The same page is the source for the thresholds above, including the higher set for taxpayers living outside the United States.

The practical order of operations

Before your preparer can do anything useful, they need the maximum balance of every Israeli account during the year, in shekels, and the year-end balance. Israeli banks do not produce this in a US-friendly format, and retrieving several years of it retroactively is unpleasant. If you are going to be doing this annually, ask your bank for an annual statement showing peak balances and keep it with your tax records.

Important. This page is general information about how US federal tax rules interact with Israeli property. It is not tax or legal advice, it is not a substitute for a licensed adviser, and it does not cover state tax, which follows its own rules. US international reporting carries severe penalties for getting it wrong — including penalties that apply even when no tax is owed. Work with a US CPA or Enrolled Agent who handles Israeli clients before you file or decide anything.

Frequently asked questions

Is the FBAR threshold per account or in total?

In total. The test is whether the aggregate maximum value of all your foreign financial accounts exceeded $10,000 at any point during the calendar year. Several small accounts that individually stay well below the threshold can cross it together, which is the most common reason people wrongly believe they have no filing obligation.

Do I report the Israeli apartment itself on Form 8938?

Generally no. Real estate held directly in your own name is not a specified foreign financial asset. The Israeli bank account connected to the property usually is reportable. If the property is held through a company or another entity, the analysis changes completely and should be reviewed with an adviser.

If I file the FBAR, do I still need Form 8938?

They are separate obligations with different thresholds, different agencies and different filing routes — FinCEN for the FBAR, the IRS with your return for Form 8938. The same account frequently appears on both. Filing one does not satisfy the other.

I live in Israel. Are my thresholds different?

For Form 8938, yes — taxpayers living abroad have substantially higher thresholds, starting at $200,000 at year end for a single filer rather than $50,000. The FBAR threshold does not change: it stays at $10,000 aggregate regardless of where you live.

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