FBAR for WISE Accounts: Main Account vs. Sub-Accounts
u/Adventurous-Peace767r/USExpatTaxesMar 29, 2026
I report all my different currency accounts (main and sub).
Answered September 2026
You report only the main account when the PFIC sub-accounts are internal holdings, but you report each one when the bank actually maintains it as a separate account; Form 8621 does not replace account reporting.
“I have a foreign bank account that automatically creates sub-accounts for PFICs I purchase. Do these sub-accounts need to be separately reported on FBAR and Form 8938, or is reporting the main bank account sufficient if the PFICs are reported on Form 8621?”
Summary
You probably do not need a separate entry for every PFIC shown under the main account if those entries are merely holdings or internal buckets. The manageable task is to confirm from the account records whether the bank created one real account or several.
Your reporting depends on what the bank actually maintains, not what its interface calls the PFIC buckets.
Internal holding or bookkeeping bucketmain only
If each automatic “sub-account” is only a position or internal ledger bucket within one , report the main account on the FBAR when the combined FBAR threshold is met and on Form 8938 when its threshold is met. Do not report each account-held again as an account: the IRS expressly says that, for both forms, the account is reportable but its stock or securities contents need not be reported separately. If you rely on Form 8621’s duplicate-reporting exception for the PFIC asset, identify the applicable Form 8621 filing in Form 8938 Part IV. (IRS Comparison of Form 8938 and FBAR Requirements, updated Sept. 18, 2025; 26 CFR 1.6038D-3(a)(1); Form 8938 Instructions, Part IV.)
Genuinely separate accountsseparate rows
If the bank’s legal and account records maintain each sub-account as a separate deposit, custody, bank, or securities account, report each account separately. For FBAR, value every account separately and enter its account number or other designation; for Form 8938, provide Part V information for each account and attach the required additional statement for each extra account. The PFIC holding inside each account is still not listed a second time as the account’s contents. (31 CFR 1010.350(c)(1)-(2); FinCEN Form 114 Instructions, Items 15 and 18; Form 8938 Instructions, Part V.)
A separate identifier is useful evidence but is not conclusive by itself; use the account agreement and full statements to determine whether the bank maintains one account or several.
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Watch out for
“Sub-account” is only a labelThe official rules classify an account by what the foreign institution maintains—a bank, securities, deposit, or custodial account—not by the word “sub-account.” A separate account number or specific identifier, statement or balance, and open/close record are strong indicators, but the official materials do not make any one indicator decisive. (31 CFR 1010.350(c)(1)-(2); Form 8938 Instructions, pp. 7 and 12.)
Form 8621 does not replace account reporting can prevent duplicate reporting of the PFIC asset on , but only when it is timely filed and identified on Form 8938. It does not report the foreign bank or custody account itself; that account remains reportable if the Form 8938 threshold is met. The same exception does not replace an . (26 CFR 1.6038D-3(a)(1) and 1.6038D-7(a)(1).)
The two thresholds are differentFBAR applies when all reportable foreign accounts together exceed $10,000 at any time. For an individual living in the United States, Form 8938 generally starts above $50,000 at year-end or $75,000 anytime if not filing jointly, and $100,000/$150,000 if filing jointly. If you meet the instructions’ living-abroad test, those figures are $200,000/$300,000 and $400,000/$600,000, respectively. For an account-held PFIC, its value is already included in the account value; do not add it a second time. (FinCEN Form 114 Instructions; Form 8938 Instructions, pp. 4–5; 26 CFR 1.6038D-5(e).)
The FBAR test is combinedAn individual account does not need to exceed $10,000 by itself. Once the combined test is met, report every reportable foreign account, and determine each actual account’s maximum value separately. (FinCEN Form 114 Instructions, “Who Must File” and Item 15.)
Many accounts have a shortcutIf the bank’s structure produces 25 or more actual foreign accounts, Item 14 of the FBAR allows you to report the account count without completing Parts II and III, but you must retain all omitted account details and produce them if requested. This shortcut does not apply to Form 8938. (FinCEN Form 114 Instructions, Item 14; Form 8938 Instructions, Part V.)
Next steps
These steps separate true accounts from investment positions and then place each item on the correct filing.
Before preparing either form
Classify each bank entry
Create an inventory with one line for each item the institution actually maintains as a bank, securities, deposit, or custodial account. Record its identifier, account type, institution, maximum balance, and opening or closing date. Treat a PFIC shown only as a position beneath the main account as account contents; use a separate row when the legal and account records show a separately maintained account. (31 CFR 1010.350(c); Form 8938 Instructions, Part V.)
Requirements
Complete annual bank or custody statement
Account-opening terms or account agreement
All account numbers or specific identifiers
Separate balance and open/close records, if any
After identifying the real accounts
Calculate the two thresholds
For FBAR, determine each actual account’s maximum calendar-year value separately and apply the combined $10,000 test across all foreign accounts. For Form 8938, apply the threshold for your filing status and location to all specified foreign financial assets; include the PFIC inside the account’s value rather than counting it twice. (FinCEN Form 114 Instructions; 26 CFR 1.6038D-5(e); Form 8938 Instructions, pp. 4–5.)
Requirements
Inventory of all foreign accounts
Maximum account values
Values of other specified foreign financial assets
Applicable year-end exchange rates
April 15, with automatic extension to October 15
File FinCEN Form 114
File the FBAR electronically through FinCEN’s BSA E-Filing System at https://bsaefiling.fincen.gov/. Enter one record for the main account if the PFIC entries are only holdings; enter one record per actual separate sub-account otherwise. For a 2025 FBAR, the automatic extended deadline is October 15, 2026, and no extension request is required. Retain the required account details for five years. (FinCEN Form 114 Instructions; IRS FBAR guidance.)
Requirements
Account inventory
Maximum value for each actual account
Institution name and address
Account number or other designation
By the tax return’s due date, including extensions
Attach Form 8938 and Form 8621 correctly
If the Form 8938 threshold is met, report each actual foreign deposit or custodial account in Part V and attach an additional statement for every additional account. Do not list the PFIC again merely because it is held inside that account; if you rely on Form 8621’s duplicate-reporting exception for a PFIC asset, enter the number of Forms 8621 in Form 8938 Part IV. Attach the applicable Forms 8621 to the same return and file them by the return’s due date, including extensions. (Form 8938 Instructions, Parts IV–V; 26 CFR 1.6038D-7(a); Form 8621 Instructions.)
Requirements
Annual federal income tax return
Form 8938 account inventory
Applicable Forms 8621
Values of assets reported on other information returns
Others who faced this
You are not the first to go through this. Here is how it went for others who asked the same thing.
Legal sources
This answer is based on FinCEN’s Form 114 instructions, Treasury regulations, and the IRS instructions for Forms 8938 and 8621.
IRS Comparison of Form 8938 and FBAR Requirements
For both Form 8938 and FBAR, securities held inside a foreign financial account are contents of the reported account, not separate account entries.
IRS Comparison of Form 8938 and FBAR Requirements
Table: Types of foreign assets and whether they are reportable
|Foreign stock or securities held in a financial account at a foreign financial institution |The account itself is subject to reporting, but the contents of the account do not have to be separately reported |The account itself is subject to reporting, but the contents of the account do not have to be separately reported |
31 CFR 1010.350
These regulations define the bank and securities accounts covered by FBAR rules.
31 CFR 1010.350
(c)(1)-(2)
The term “bank account” means a savings deposit, demand deposit, checking, or any other account maintained with a person engaged in the business of banking. The term “securities account” means an account with a person engaged in the business of buying, selling, holding or trading stock or other securities.
FinCEN Form 114 Instructions
This establishes the combined FBAR threshold and the separate valuation and identification of each actual account.
FinCEN Form 114 Instructions
General Instructions; Items 15 and 18
A United States person that has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year. For Item 15, if the filer had a financial interest in more than one account, each account must be valued separately. Item 18. Provide the account number used by the financial institution to designate the account.
26 CFR 1.6038D-3
Form 8938 reports the foreign financial account, while an asset held inside it is not reported separately.
26 CFR 1.6038D-3
(a)(1)
Except as otherwise provided in this section, a specified foreign financial asset includes any financial account maintained by a foreign financial institution. An asset held in a financial account maintained by a foreign financial institution is not required to be separately reported on Form 8938, “Statement of Specified Foreign Financial Assets.”
Instructions for Form 8938
Each actual foreign account receives its own Form 8938 information, and the form is attached to the annual return.
Instructions for Form 8938
When and How To File; Part V
If you have more than one account, attach an additional statement with the required information for each additional account and check the box at the top of page 1 of the form. Attach Form 8938 to your annual return and file by the due date (including extensions) for that return.
26 CFR 1.6038D-7
A timely Form 8621 can eliminate duplicate Form 8938 reporting of the same PFIC asset, but Form 8938 must identify that filing.
26 CFR 1.6038D-7
(a)(1)(C), (a)(1)(ii)
( C ) Form 8621, “Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund”; ( ii ) Reports on Form 8938 the filing of the form on which the asset is reported.
26 CFR 1.6038D-5
An account-held PFIC’s value is included in the account value rather than added again as a separate account asset.
26 CFR 1.6038D-5
(e)
The value of an asset held in a financial account maintained by a foreign financial institution is included in determining the maximum value of that account.
Instructions for Form 8938
Form 8938 thresholds depend on filing status and whether the instructions’ living-abroad requirements are met.
Instructions for Form 8938
Reporting Thresholds Applying to Specified Individuals
If you are married and file a separate income tax return from your spouse, you satisfy the reporting threshold only if the total value of your specified foreign financial assets is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year. If you are married and you and your spouse file a joint income tax return, you satisfy the reporting threshold only if the total value of your specified foreign financial assets is more than $400,000 on the last day of the tax year or more than $600,000 at any time during the tax year.
FinCEN Form 114 Instructions
FBAR filers with at least 25 accounts receive abbreviated reporting but must keep the omitted details.
FinCEN Form 114 Instructions
Item 14, page 15
14. a) Does the filer have a financial interest in 25 or more financial accounts? (Check if) Yes (* Enter total number of accounts in space provided) Do not complete Part II or Part III, but maintain records of the information.
Instructions for Form 8621
Form 8621 ordinarily accompanies the shareholder’s tax return by that return’s extended due date.
Instructions for Form 8621
When and Where To File
Attach Form 8621 to the shareholder's tax return (or, if applicable, partnership or exempt organization return) and file both by the due date, including extensions, of the return at the Internal Revenue Service Center where the tax return is required to be filed.
These are the official rules as published on the cited dates; tax and financial-reporting rules can change.
This is general information about official processes, not legal advice, and SettleKit is not a law firm.
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