Statement of Specified Foreign Financial Assets

Who Files Form 8938

US persons whose specified foreign financial assets exceed the IRS thresholds: $50,000 end-of-year or $75,000 anytime for single US-resident filers; $100,000 / $150,000 for joint US-resident filers; significantly higher thresholds for filers living abroad. Specified domestic entities (certain US partnerships and corporations) may also need to file.

What Form 8938 Reports

Reportable assets include foreign accounts, foreign stocks held outside an account, foreign mutual funds, certain foreign partnership and trust interests, and foreign-issued life insurance with cash value. Form 8938 supplements but does not replace the FBAR (FinCEN 114): many taxpayers must file both.

Key Deadlines

• Filed with Form 1040 by April 15
• Automatic six-month extension when Form 4868 is filed for the personal return

Common Mistakes

• Filing FBAR but missing Form 8938 (or vice versa): they have different thresholds and definitions
• Misreporting foreign mutual fund holdings as PFICs without the corresponding Form 8621
• Missing reporting on foreign retirement accounts (401(k)-equivalents in foreign jurisdictions)
• Penalty stacking when both Form 8938 and Form 5471 / 5472 are missed

Best Practices

• File Form 8938 in addition to FBAR when both apply. Many taxpayers think one replaces the other; they do not.
• Use the higher residency-based threshold if you live abroad. Single overseas filers do not file Form 8938 until $200K end-of-year or $300K anytime.
• Report foreign mutual funds and ETFs as PFICs on Form 8621 too. Form 8938 reporting alone does not satisfy the PFIC obligation.
• Track value in USD using year-end exchange rates from Treasury Reporting Rates of Exchange (the IRS-preferred source).
• For foreign retirement accounts (UK SIPP, Canadian RRSP, Australian Super), consult on whether and how to report the underlying funds and whether a treaty election is available.

Source: Official Form 8938 information at IRS.gov