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Choose a tax professional who regularly handles both the U.S. FBAR (FinCEN Report 114) and IRS Form 8938, can explain why each form does or does not apply to you, and accepts clear responsibility for preparing, reviewing, and submitting every required filing. Then verify the person’s credential, active PTIN, relevant experience, fee, review process, and availability after filing.
Neither a credential nor a listing in the IRS directory proves expertise with your particular foreign accounts, entities, trusts, ownership interests, or residency history. Your selection should be based on the professional’s analysis of your facts and on a documented process that leaves you with complete copies and submission confirmations.
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Start with the two reporting systems, not the word “foreign”
Foreign-account reporting is not one filing. The FBAR and Form 8938 are separate requirements administered through different channels, with different definitions and thresholds. A preparer who treats them as interchangeable can leave an otherwise compliant taxpayer exposed.
FBAR: FinCEN Report 114
The FBAR reports qualifying foreign financial accounts under the Bank Secrecy Act. It is filed electronically with the Financial Crimes Enforcement Network (FinCEN), not attached to your federal income-tax return. The Taxpayer Advocate Service describes it as a calendar-year report due April 15 of the following calendar year. Confirm the current year’s instructions, exceptions, and any applicable relief rather than relying on an old calendar.
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If you authorize another person to submit an FBAR electronically for you, the Taxpayer Advocate Service identifies FinCEN Form 114a, Record of Authorization to Electronically File FBARs, as the authorization record to complete and retain. Ask the preparer whether that form is needed and how it will be stored with your records.
Form 8938: specified foreign financial assets
Form 8938 reports specified foreign financial assets to the IRS when the applicable conditions are met. When required, it is attached to your federal income-tax return. It does not replace an FBAR. An account or asset can fall within both regimes, only one regime, or neither, depending on the asset, your interest or authority, its value, your filing status, residence, and other facts.
Published Form 8938 thresholds are fact-specific
The IRS international-tax FAQ, updated February 26, 2024, states these thresholds for unmarried U.S. citizens and residents living in the United States: specified foreign financial assets exceeding $50,000 on the last day of the tax year or $75,000 at any time during the year. For married taxpayers filing jointly in that same residence context, the figures are $100,000 on the last day or $150,000 at any time.
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Those figures are not universal thresholds. Filing status and whether you live in the United States or abroad can change the analysis, and FBAR rules remain separate. A good professional will show you which threshold and definition is being applied instead of answering from a single account balance.
What a qualified professional should be able to explain
During an initial conversation, the preparer should be able to map your facts to each filing obligation. You should receive a reasoned explanation—not merely “you have a foreign account” or “your balance was under the limit.”
Ownership, authority, and account type
Ask how the professional treats accounts you own individually, hold jointly, control through a business, or can access through signature or other authority. The same review should cover brokerage and securities accounts, insurance or retirement arrangements, and interests connected to foreign entities or trusts when those facts are present. The relevant question is not only whose name appears on a statement; it is what legal or practical interest and authority you had during the year.
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Value and timing
Request instructions for identifying each account’s maximum value during the year, the currency used, and the conversion method. Form 8938 and FBAR calculations can look at different concepts and time periods. The professional should tell you which date, maximum, or valuation evidence is needed for each form and how estimates or unavailable records will be documented.
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Tell the candidate where you lived during the year, your citizenship or residency status, and whether you filed single, jointly, separately, or under another status. These facts can alter Form 8938 thresholds and the scope of the review. If you moved countries, expatriated, or had a nonstandard residency position, ask directly whether the professional handles those cases.
Credentials, PTINs, and representation rights
Verify the baseline: an active PTIN
A person paid to prepare federal tax returns generally must have an active IRS preparer tax identification number (PTIN). Ask for the preparer’s PTIN status and confirm that the person who signs your federal return is properly authorized for paid preparation. A PTIN is a baseline authorization; it is not evidence of international-tax specialization.
Understand what each credential means
The IRS describes enrolled agents (EAs) as IRS-licensed professionals subject to suitability checks, a three-part examination or qualifying experience, and continuing-education requirements. Certified public accountants (CPAs) are licensed by state boards and must satisfy that jurisdiction’s examination, education, experience, ethics, and continuing-education rules. Attorneys are licensed by state courts or bars.
EAs, CPAs, and attorneys have unlimited representation rights before the IRS. Other preparers may have narrower rights, limited to returns they prepared or to particular proceedings. Ask what representation the candidate can provide if the IRS questions your return or requests records. Verify an EA through the IRS, a CPA through the relevant state board, or an attorney through the appropriate state licensing authority.
Use the IRS directory carefully
The IRS Directory of Federal Tax Return Preparers with Credentials and Select Qualifications includes attorneys, CPAs, EAs, certain other credentialed preparers, and specified Annual Filing Season Program participants with valid PTINs. It is not a complete list of every valid paid preparer. The IRS says a preparer may be absent because the person lacks one of the listed qualifications, opted out, or has a new or changed entry that has not appeared yet.
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Use a directory result as one verification step, not as a ranking. If a candidate is absent, ask about the person’s education, training, current credential, PTIN, and experience with FBAR and Form 8938. If a candidate appears, independently confirm that the credential and licensing information is current.
Compare candidates on the work they will actually do
Obtain the same information from every plausible professional so that you can compare service, not just titles.
| Selection point | What to ask | What a satisfactory answer includes |
|---|---|---|
| Relevant experience | How often do you handle cases resembling mine? | Specific discussion of facts such as joint accounts, signature authority, foreign entities, trusts, expatriation, or cross-border residence when relevant; no invented minimum case count is required. |
| Scope | Who prepares and submits the federal return, Form 8938, and FBAR? | A named person for each filing, whether FBAR is included, and an explanation of any work assigned to another specialist. |
| Review | Who checks the forms before submission? | A defined review step and a chance for you to inspect the completed information. |
| Records | What will you need from me? | Account statements, maximum balances, ownership or authority details, foreign tax documents, and other records matched to the forms. |
| Representation | Can you represent me if the IRS contacts me? | The limits of the person’s credential and a clear description of what is included or billed separately. |
| Fees | What does the quoted fee cover? | Separate treatment of the federal return, Form 8938, FBAR, authorization paperwork, amendments, correspondence, and additional review. |
| Continuity | Who answers questions after filing season? | A contact method, expected response process, and availability for later notices or corrections. |
| Delivery | What will I receive? | A complete copy of every filed return and report, submission confirmations, and retained authorization records. |
Questions to ask before signing an engagement
- “How will you determine whether my facts require FBAR, Form 8938, both, or neither?” The answer should address account type, ownership or authority, values, filing status, residence, and relevant exceptions.
- “Who prepares and submits each filing?” Confirm whether the same firm handles the income-tax return and FBAR, coordinates with another specialist, or expects you to file one item yourself.
- “Is the FBAR included in the engagement fee?” Obtain the answer in writing, including any separate charge for Form 114a or corrections.
- “Which records and maximum balances do you need?” Ask whether statements must cover the whole year and how foreign-currency amounts should be supplied.
- “Who reviews the forms before filing?” Find out whether the preparer or a second professional performs the final check and when you will see the completed forms.
- “What credential do you hold, is your PTIN current, and what representation rights apply?” Verify the answer through the relevant licensing source.
- “What happens if the IRS or FinCEN contacts me later?” Clarify what post-filing assistance costs and how long the professional remains available.
- “Will I receive copies and proof of submission?” Your engagement should produce a complete, readable record for your files.
These questions screen a service provider; they do not substitute for individualized tax or legal advice. Tell the professional at the outset about foreign trusts, entities, expatriation, previous nonfiling, or possible penalties. Ask whether that exact work is within the person’s competence and engagement scope.
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- Account statements showing the account holder, account number or identifier, institution, country, and year-end and maximum values.
- Ownership percentages, joint-owner details, beneficiary or controlling-person information, and documentation of signature or other authority.
- Foreign-currency amounts and the source or method used for conversion to U.S. dollars.
- Records for accounts opened, closed, transferred, or changed during the year.
- Foreign tax paid, withholding statements, and documents showing income associated with the account or asset.
- Formation, ownership, distribution, or control documents for foreign companies, partnerships, trusts, or similar arrangements.
- Prior federal returns, prior FBARs, prior Forms 8938, and correspondence about foreign-account reporting.
- Residency, immigration, citizenship, and filing-status information when those facts affect the analysis.
Do not send only a year-end balance. The professional may need the highest value during the year, authority held without ownership, and documents explaining a structure that does not appear on a personal bank statement.
Make the engagement and fee boundaries explicit
A written engagement should identify each deliverable. It should say whether the fee covers the federal income-tax return, Form 8938, FBAR preparation and electronic submission, Form 114a when applicable, estimated-tax work, amended filings, responses to notices, and post-filing consultations.
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Ask how the firm charges for additional entities, multiple accounts, late or amended filings, translation, missing records, and representation. The IRS warns taxpayers to avoid fees based on a percentage of a refund. A flat or clearly itemized arrangement makes it easier to see what foreign-account work is included.
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- Initial fact review: Give the professional a complete account, ownership, authority, residency, and filing-status summary before accepting a quote.
- Obligation map: Obtain a written or clearly documented explanation identifying FBAR, Form 8938, both, or neither, with the facts supporting the conclusion.
- Record reconciliation: Match every account or asset to statements, maximum values, currency conversions, and ownership or authority evidence.
- Draft preparation: Review the federal return and each foreign-account report for names, account identifiers, countries, values, ownership categories, and filing status.
- Client approval: Correct omissions before submission. Never sign a blank return or approve figures you do not understand.
- Electronic submission: Confirm that the federal return and FBAR are sent through their respective systems and that any required authorization is completed.
- Record delivery: Retain the filed return, Form 8938, FBAR confirmation, Form 114a if used, worksheets, and correspondence in a secure location.
The IRS states in Tax Tip 2025-11, published February 6, 2025: “Taxpayers are ultimately responsible for all the information on their federal income tax return, regardless of who prepares the return.” Your review is therefore a substantive safeguard, not a formality.
Recognize warning signs before you pay or sign
- The preparer says Form 8938 automatically replaces the FBAR, or says one balance alone determines every obligation.
- The person refuses to explain which filing channel is being used or who is responsible for submission.
- You are asked to sign a blank return, are not given a copy, or cannot review the completed information.
- The professional will not provide a current credential, licensing information, or PTIN status.
- The quote is vague about FBAR, Form 8938, amendments, notices, or post-filing assistance.
- The preparer guarantees a result, discourages questions, or asks that a refund be sent to an account you do not control.
- The firm claims broad international expertise but cannot discuss your ownership, authority, residency, trust, or entity facts.
The IRS also recommends considering whether a preparer will remain available if questions arise later and ensuring that refunds go to your own account.
When your facts call for a specialist or coordinated team
A general return preparer may be suitable for a straightforward account, but more complicated facts deserve a direct capability check. Foreign trusts, foreign corporations or partnerships, expatriation, prior nonfiling, potential penalties, multiple jurisdictions, and unclear ownership can involve rules beyond the two forms themselves.
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Ask whether the candidate personally handles that category, works with an EA, CPA, or attorney who does, or will refer the matter before preparation begins. If two professionals are involved, assign responsibility in writing: who gathers facts, who determines the reporting position, who prepares each form, who signs, and who answers an examination or notice.
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Check timing without assuming an extension
FBAR is a calendar-year report with the April 15 following-year due date described by the Taxpayer Advocate Service. Form 8938 follows the federal income-tax return’s filing context when applicable. Deadlines, automatic extensions, disaster relief, and exceptions can change by year and circumstance, so confirm the current instructions with the professional and the official agencies.
Start early enough to obtain maximum-balance records and resolve ownership questions. A last-minute preparer may have no time to investigate an unfamiliar trust, reconcile currencies, or coordinate a separate FBAR submission.
A practical decision framework
After interviewing candidates, choose the person who can demonstrate all of the following:
- Correct scope: The professional distinguishes FBAR from Form 8938 and can explain why each applies or does not apply to your facts.
- Documented authority: The person has a verifiable credential or clearly disclosed qualification, an active PTIN when required, and representation rights suited to your risk.
- Comparable experience: The candidate can discuss cases with the same kinds of ownership, authority, accounts, entities, trusts, or residency issues you have.
- Defined ownership: The engagement names who prepares, reviews, files, and follows up on every required item.
- Transparent cost: The fee identifies included forms, additional work, amendments, and post-filing assistance without refund-based pricing.
- Reliable records: You will receive complete copies, confirmations, and any authorization documents.
- Accessible follow-up: You know how to reach the professional if a statement changes, a correction is needed, or an agency sends a notice.
No official source ranks one credential as universally best for every foreign-account situation, and no published minimum number of FBAR or Form 8938 cases guarantees quality. The best choice is the professional who can substantiate the analysis, communicate the limits of the engagement, and maintain a verifiable filing record.
After filing: keep the relationship useful
Store the filed return and reports with the statements and calculations used to prepare them. Keep submission confirmations and Form 114a where applicable. Record the professional’s contact process and the date on which the engagement’s post-filing support ends.
For the next tax year, update the file for new accounts, closures, transfers, changed ownership, changed residence, and changes in filing status. Give the preparer prior-year copies rather than assuming the same accounts and values will apply. If you discover an omission, contact the professional promptly and ask what corrective filing or advice is appropriate; do not quietly alter a future return and assume it fixes an earlier year.
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