FBAR vs Form 8938: Chinese Bank Accounts, WeChat Pay and Alipay

Life in the USOct 18, 2026 · 7 min read

Almost every Chinese immigrant in the US still has something back home: a bank card from college, a time deposit your parents opened in your name, an A-share brokerage account, a cash-value insurance policy, and of course WeChat Pay and Alipay. Once you become a US tax resident, the US expects you to report those accounts, even if they earn almost nothing and you never move the money. Two forms do the job, and they are easy to confuse. This guide explains both, using the same rules and thresholds as our free Tax Self-Check questionnaire, which was built from the IRS and FinCEN instructions.

Step 1: are you a "US person"?

Both the FBAR and Form 8938 apply only to US persons. Nonresident aliens generally don't file either. You are a US person for these rules if you are:

• A US citizen, wherever you live.
• A green card holder (the green card test).
• A visa holder who meets the substantial presence test. You need at least 31 days in the US this year, and 183 days over three years counting all of this year's days, one third of last year's and one sixth of the year before.

Students and some scholars get a break. Days spent in F, J, M or Q status don't count while you are an exempt individual:

• Students (F-1, J-1 student, M, Q): exempt for the first 5 calendar years. Any part of a year counts as a whole year, so arriving in August 2021 uses up 2021.
• Teachers, trainees and researchers (J-1 or Q non-students): not exempt if you were already exempt for any part of 2 of the 6 preceding calendar years.

Exempt individuals file Form 8843 each year, even with no income. So a typical F-1 student becomes a resident either in their sixth calendar year in the US or, after switching to H-1B, in the first year their H-1B days are enough to meet the test (with a mid-year switch, that is often the following year). That is the first year the FBAR and Form 8938 can apply. In a year when you become a resident partway through (a dual-status year), Form 8938 applies because it covers anyone who was a resident alien for any part of the year. Our Tax Self-Check also notes that in your first year as a resident, the FBAR covers your accounts for the whole calendar year.

FBAR (FinCEN Form 114)

• Who: a US person with a financial interest in, or signature authority over, foreign financial accounts.
• Threshold: the aggregate maximum value of all those accounts exceeded $10,000 at any time during the calendar year. This number is fixed by law and not adjusted for inflation.
• How: filed online through FinCEN's BSA E-Filing System, not with your tax return and not with the IRS.
• When: due April 15, with an automatic extension to October 15. You don't have to request it.

"Aggregate maximum value" trips people up. Take each account's highest balance during the year, convert it to dollars at the Treasury Reporting Rate of Exchange for the last day of the year, and add them up. No single account has to be over $10,000. For tax year 2025 the Treasury year-end rate was 6.998 yuan per dollar. If your ICBC savings peaked at ¥50,000 and a CCB account peaked at ¥30,000, that is ¥80,000, or about $11,430, so you file, and you list both accounts.

A few more rules worth knowing:

• Joint accounts: each owner reports the account at its full value. Spouses can file one joint FBAR (Form 114a).
• Signature authority counts. If your parents' account lists you as someone who can operate it, that can make it reportable on your FBAR even though the money isn't yours.
• Penalties: the non-willful civil penalty can be up to $16,536 per report (2025 inflation adjustment). After the Supreme Court's 2023 Bittner decision it is counted per report, not per account.
• Virtual currency: an account holding only crypto is not reportable on the FBAR for now (FinCEN Notice 2020-2), though FinCEN has said it plans to change that.

Form 8938 (FATCA)

Form 8938 comes from the Foreign Account Tax Compliance Act. It is filed with the IRS as an attachment to your Form 1040, and you only need it if you have to file a tax return for the year. It covers "specified foreign financial assets", which include foreign bank and brokerage accounts but also some things the FBAR doesn't, such as an interest in a foreign pension plan.

You file if the total value is over the year-end threshold on December 31 or over the any-time threshold at any point in the year. These amounts are not indexed for inflation.

Unlike the FBAR, accounts where you only have signature authority don't count for Form 8938, and a joint account with your spouse counts once on a joint return.

FBAR vs Form 8938 side by side

Filing one does not replace the other. Someone single in the US with ¥600,000 in Chinese savings (roughly $86,000 at the 2025 year-end rate) is over both lines and files both.

Which Chinese accounts count?

• Bank accounts (savings, current and time deposits, including the debit card linked to them): yes, for both forms.
• Brokerage or securities accounts (A-shares, funds held at a bank or broker): yes.
• Insurance or annuities with a cash value: yes.
• Pensions and the housing provident fund (社保 / 公积金): the Form 8938 instructions list an interest in a foreign pension plan. We found no FinCEN guidance specific to Chinese social insurance or housing-fund accounts for the FBAR, so treat that as uncertain.
• Accounts in your parents' name: only if you have a financial interest or signature authority.

WeChat Pay and Alipay

This is the question everyone asks, and the honest answer is that nobody official has said. We found no IRS or FinCEN guidance on whether a WeChat Pay balance (零钱 / 零钱通) or an Alipay balance or Yu'ebao (余额宝) is a "financial account" for the FBAR or Form 8938. The FBAR rules cover accounts with "a financial institution (or other person performing the services of a financial institution)", and many filers include these balances to be safe. That is a judgment call, not a rule. If your total only crosses $10,000 when the e-wallets are counted, talk to a CPA or enrolled agent who handles international returns. Tax Self-Check marks these accounts as "Uncertain" and tells you whether they change your answer.

Money from your parents: Form 3520

A related form catches many families. If you are a US person and in one tax year you receive more than $100,000 in gifts or inheritances from nonresident alien individuals or foreign estates, such as your parents in China, you report it on Form 3520. Gifts from related people (for example, both parents) are added together, and each gift over $5,000 is listed. The gift itself is generally not taxed. Form 3520 is mailed to the IRS separately from your return, is due when your return is due (and extended if you extend), and the penalty for not filing is 5% of the gift per month, up to 25%. Gifts from foreign corporations or partnerships have a much lower threshold: $20,116 for 2025 and $20,573 for 2026. If you're moving that money to or from China, our guide to sending money to China covers the SAFE quota and US reporting from the sender's side.

How Tax Self-Check helps

Tax Self-Check walks you through residency (it runs the substantial presence test and the F/J exempt-year rules), then lets you list each foreign account in yuan or another currency. It converts them at the Treasury rate, adds up the FBAR and Form 8938 totals, flags the uncertain e-wallet and pension entries, checks Form 3520, and ends with a checklist of forms, deadlines and official links. It runs in your browser in English or Chinese with no account. For the other direction, the US→China Transfer Calculator compares wire, Wise, Remitly and Western Union costs. If you're on F-1 or OPT, the H-1B Odds & OPT Timeline helps you see when your status, and so your tax residency, may change.

FAQ

I'm on F-1. Do I need to file an FBAR?

Usually not in your first five calendar years as a student, because you are an exempt individual and generally a nonresident alien, and the FBAR applies to US persons. You still file Form 8843 every year. Once you become a resident, for example in your sixth calendar year or once your H-1B days meet the substantial presence test, the FBAR rules apply.

Do I still file an FBAR if I file Form 8938?

Yes, if you meet both thresholds. They are separate requirements filed with different agencies: the FBAR with FinCEN online, Form 8938 with the IRS on your tax return.

Are WeChat Pay and Alipay balances reportable?

There is no official IRS or FinCEN guidance either way. Many people include them to be safe. If including them is what puts you over a threshold, ask a tax professional before you decide.

What if I missed FBARs in past years?

File as soon as you can. The IRS describes options for people who missed foreign-account filings, including the streamlined filing compliance procedures for non-willful cases. A professional can tell you which route fits your situation.

Is the money my parents send me taxable?

A gift from your parents is generally not taxable income to you. But if gifts from foreign individuals total more than $100,000 in a tax year and you are a US person, you must report them on Form 3520.

Sources

• FinCEN: Report Foreign Bank and Financial Accounts (FBAR)
• IRS: Report of Foreign Bank and Financial Accounts (FBAR)
• FinCEN: FBAR line item filing instructions (PDF)
• FinCEN: Reporting jointly held accounts
• FinCEN BSA E-Filing System
• IRS: Comparison of Form 8938 and FBAR requirements
• IRS: Instructions for Form 8938
• IRS: Substantial presence test
• IRS: Exempt individual, who is a student
• IRS Publication 519, US Tax Guide for Aliens
• IRS: Instructions for Form 3520
• IRS Rev. Proc. 2025-32 (2026 inflation adjustments, PDF)
• Treasury Reporting Rates of Exchange
• IRS: Streamlined filing compliance procedures

Last updated 2026-10-18. This guide is general information, not tax or legal advice. Thresholds and rules are as stated by the IRS and FinCEN as of October 2026; check the official pages above and talk to a qualified tax professional about your own situation.