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You may not have to file a Form 8938, Statement of Specified Foreign Financial Assets but you may be required to file the FBAR FinCEN Form 114.  The Form 114 is not filed with the IRS. It must be filed directly with the office of Financial Crimes Enforcement Network (FinCEN), a bureau of the Department of the Treasury, separate from the IRS. 

 

Go to this IRS website for a comparison between the Form 8938 and FinCEN Form 114 along with how to file, if required - https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements