What is Form 8938?
Updated on September 09, 2025
Published by
Reviewed by
Rose-ann De Villa, an IRS Enrolled Agent and CPA with 14 years of expat tax experience, specializes in US tax preparation, tax planning, and tax advice for US citizens and Green Card holders living and working in the UK.
Rose-ann has been mentioned in the Daily Express UK news wherein she talked about Stimulus payments and Child Tax Credit refunds for US expats in the UK.
Table of Contents
Who needs to file Form 8938 and when?
Form 8938 is a US tax form used to report certain foreign financial accounts and assets if their total value exceeds specific thresholds.
Who has to file?
US citizens, Green Card holders, and anyone treated as a US tax resident who lives in a foreign nation.
How does Form 8938 fit with the rest of your filing?
You attach it to Form 1040. It sits alongside the FBAR, which has different rules and a much lower threshold. It can also coexist with forms triggered by certain investments, like Form 8621 for some funds, or 3520/3520-A in trust situations.
Do ISAs and SIPPs show up on Form 8938?
In most cases, yes, because they are foreign financial accounts or interests. Directly owned foreign property isn’t listed, but a company or fund that holds that property usually is. A SIPP always triggers 3520/3520-A filings, but it also appears on Form 8938 as a foreign pension except when it is considered an excepted foreign financial asset.
Form 8938 thresholds for Americans living abroad
US expats file Form 8938 if their specified foreign assets exceed US$200,000 (single) or US$400,000 (married filing jointly) at year-end.
- Single, head of household or married filing separately: File if total specified assets are at least US$200,000 on the last day of the tax year, or more than US$300,000 at any time during the year.
- Married filing jointly: File if totals are at least US$400,000 on the last day of the tax year, or more than US$600,000 at any time during the year.
Which assets count toward those totals?
Bank current and savings accounts, foreign brokerage accounts, ISAs, SIPPs and many employer pensions, foreign mutual funds or OEICs, NS&I products such as Premium Bonds, certain life policies with cash value, and interests in foreign partnerships or companies.
đź“ŚDocumentation tips to keep this simple
- Capture the highest balances. Save monthly or quarterly statements that show peaks. For pensions, keep provider valuations that show year-end and highest values.
- Be consistent with exchange rates. Convert to US dollars using a reasonable and consistent source. Many filers use a year-end spot rate for 31 December values and a yearly average when needed. Note the source and date.
- Keep a one-page worksheet. List each account or asset, the highest balance, the 31 December balance, and the USD conversion used. This helps the Form 8938 tables line up with your FBAR.
- Match names across forms. If an account appears on the FBAR and you meet the Form 8938 thresholds, list it here too using the same institution name and country. That consistency reduces follow-up questions.
What counts as a specified foreign financial asset?
If you live outside of the US and meet the filing thresholds, here’s what usually counts.
- Foreign bank and brokerage accounts. Current and savings accounts, building society accounts, and foreign investing platforms are in scope.
- Do ISAs count? Yes. Cash and stocks & shares ISAs are foreign financial accounts for Form 8938.
- Custodial accounts and certain insurance or pension interests. Accounts where a custodian holds investments for you are included. Life policies with cash value are typically reportable.
- What about SIPPs and employer pensions? Many SIPPs and workplace schemes are reportable interests for Form 8938, so keep year-end and highest-value statements.
- Foreign securities held outside an account. If you directly hold foreign shares, gilts, or units in a foreign fund outside a platform, you still report the fair market value.
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Form 8938 vs FBAR for foreign accounts: what overlaps and what doesn’t
If you’re comparing Form 8938 and FBAR, many of the same accounts appear on both forms once each form’s trigger is met. The key differences are scope, thresholds, and where you file.
Here’s what each form covers
- Form 8938 (IRS, with your 1040): foreign financial accounts plus certain non-account assets (for example, directly held shares, interests in foreign entities, cash-value life policies, some pensions).
- FBAR (FinCEN Form 114, filed with Treasury): accounts only (bank, brokerage, pension accounts, certain insurance accounts).
Thresholds and triggers
- Form 8938: higher thresholds for foreign-living filers, with separate “last-day” and “anytime” tests across all specified assets.
- FBAR: low threshold. If the aggregate of all foreign accounts exceeds US$10,000 at any time during the year, you file.
Filing location
- Form 8938: attach to your US return.
- FBAR: submit separately online through the BSA e-Filing system.
Signature authority without ownership
- Form 8938: generally not reportable if you only have signature authority and no financial interest.
- FBAR: reportable with signature or other authority over an account, even if it isn’t yours (limited exceptions apply).
Valuation and currency
- Form 8938: use a reasonable, consistent USD conversion; support highest and year-end values.
- FBAR: use the official year-end rate and report each account’s maximum value during the year.
When are both required?
If your foreign accounts push you over US$10,000 at any time, you file an FBAR. And if your specified assets also meet the Form 8938 thresholds for someone living abroad, you include them on Form 8938 as well.
Filing steps, deadlines, and mistakes US expats should avoid
Steps that keep the process simple
- List every specified asset first, then total them.
- Check the abroad thresholds: single, head of household or married filing separately file at US$200,000 on 31 December or over US$300,000 at any time; married filing jointly file at US$400,000 on 31 December or over US$600,000 at any time.
- Complete the Form 8938 sections that apply. Most people use Part I for accounts and Part II for other assets.
- Attach Form 8938 to Form 1040 and keep your backup.
Deadlines for US expats
It follows your US return. Living abroad generally gives you an automatic extension to June 15. You can extend to October 15 by filing Form 4868.
Mistakes to avoid
- Closed or dormant accounts: If they held money at any point in the year, include them.
- Forgotten pensions: Old workplace schemes and small SIPPs are easy to miss.
- Inconsistent exchange rates: Pick a reasonable source, apply it the same way each year, and note it.
- Assuming Form 8938 replaces FBAR: It doesn’t. FBAR covers accounts only and uses the official year-end rate.
- Poor records: Keep a simple worksheet that lists each asset, the highest value, the 31 December value, and the USD rate used. Save PDFs of statements that show peaks and year-end figures.
FAQs
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I moved overseas mid-year, which thresholds apply to me?
Use the higher expat thresholds only if you meet the IRS “living abroad” definition for the year (tax home abroad and sufficient days overseas); otherwise, use the domestic thresholds (US$50k/US$75k single/MFS; US$100k/US$150k MFJ).
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I’m not otherwise required to file a US tax return, do I still file Form 8938?
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On a joint return with my non-US spouse, whose assets count?
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Do I list each asset separately or can I just report totals?
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I forgot to file Form 8938, how do I fix it?
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