$10,000 — FBAR threshold — aggregate foreign account balance
| Feature | FBAR (FinCEN 114) | FATCA (Form 8938) |
|---|---|---|
| Filed with | FinCEN (separate portal) | IRS (attached to Form 1040) |
| Threshold (single) | $10,000 aggregate, any day | $50,000 year-end / $75,000 any day |
| Threshold (joint) | $10,000 aggregate, any day | $100,000 year-end / $150,000 any day |
| Due date | April 15 (auto-ext. Oct 15) | Same as Form 1040 (incl. extensions) |
| Covers | Bank and financial accounts | Broader 'specified foreign financial assets' |
| Penalty (non-willful) | Up to $10,000/year | Up to $10,000 (+ $10,000/30 days after notice) |
| Penalty (willful) | Greater of $100K or 50% of balance | Up to $50,000 |
$19,000 — 2025 annual gift tax exclusion per recipient
| Situation | Form Required | Filing Deadline |
|---|---|---|
| Foreign account(s) exceeded $10K any day | FBAR (FinCEN 114) | Oct 15 (auto-ext.) |
| Foreign assets exceeded $50K/$100K threshold | Form 8938 (FATCA) | With Form 1040 |
| Sent >$19K to one person in a year | Form 709 (Gift Tax Return) | April 15 (ext. to Oct 15) |
| Received >$100K from foreign person | Form 3520 | With Form 1040 |
| Sold or swapped crypto before sending | Form 8949 + Schedule D | With Form 1040 |
| Earned interest on foreign account | Schedule B (Part III) | With Form 1040 |
5%/month — Penalty for failing to file Form 3520
No. Remittances are treated as gifts, not income, and the recipient abroad owes no US tax. As the sender, you do not owe gift tax unless you send more than $19,000 (2025) to a single person in a year—and even then, gift tax is typically not owed until you exhaust your lifetime exemption ($13.99 million in 2025). However, you may be required to file Form 709 to report the gift.
If you have signature authority over the account—meaning you can direct withdrawals or transfers even if you are not the legal owner—it must be included in your FBAR calculation. Simply being listed as a backup contact does not create an obligation, but joint ownership or power of attorney over a foreign account generally does.
Buying USDC with US dollars is not a taxable event because USDC is pegged 1:1 to USD and there is no gain or loss. Sending USDC on Stellar or another network is also not taxable—it is a transfer, not a sale. The taxable event occurs only if you acquire USDC by selling an appreciated crypto asset (like Bitcoin). If you fund remittances by buying USDC directly with dollars, your crypto tax exposure is essentially zero.
Both report foreign financial assets, but they are filed with different agencies (FBAR with FinCEN, Form 8938 with the IRS), have different thresholds, and cover slightly different asset types. Form 8938 covers a broader category of 'specified foreign financial assets' including foreign stocks and securities held outside a foreign financial institution. Many people who must file FBAR also file Form 8938, but the thresholds are different so it is possible to have one obligation without the other.
If you receive more than $100,000 in aggregate from foreign individuals during a tax year, you must file Form 3520. No tax is due on the receipt of a foreign gift itself, but the form is mandatory and penalties for non-filing are steep (5% per month, up to 25% of the gift amount). Amounts under $100,000 from foreign persons do not require Form 3520.
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