How to fill out Form 8938 (foreign assets), line by line
Form 8938, Statement of Specified Foreign Financial Assets, is an attachment to an annual or amended tax return. First establish whether the filing route and reporting threshold apply. Then complete the detailed account or asset records on page 2 and use them to complete the summaries on page 1.
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This guide explains the supplied IRS form and instructions, not an individual filing position. The form and instructions are continuous-use materials; the IRS directs readers to IRS.gov/Form8938 for the most recent version.
Start with the Form 8938 filing route
Owning a foreign account alone does not establish that Form 8938 is required. Unless an exception applies, the form applies when a specified person has an interest in specified foreign financial assets and their total value is more than the applicable reporting threshold. A specified person is either a specified individual or a specified domestic entity.
Who may be a specified person
Specified individuals include U.S. citizens, resident aliens for any part of the year subject to the reporting-period rule, certain nonresident aliens who elect resident treatment for a joint return, and certain bona fide residents of American Samoa or Puerto Rico. Line 3 records whether the filer is an individual, partnership, corporation, or trust. The passive-income, ownership, and trust tests for specified domestic entities are specialized; use the IRS instructions under “Specified Domestic Entity” and “Excepted Specified Domestic Entities” for that analysis.
Attach Form 8938 to the annual return or amended return; do not send it to the IRS by itself.
File it by the due date of that return, including extensions.
If you do not have to file an income tax return for the year, you do not have to file Form 8938, even if asset value exceeds the otherwise applicable threshold.
Form 8938 and FBAR are separate filings
Form 8938 does not replace an otherwise required FinCEN Form 114, commonly called FBAR. Assess FBAR separately using FinCEN Form 114 and its instructions.
Check whether your assets exceed the Form 8938 threshold
For a specified individual, select the row that matches where you live and how you file, then compare the total value of specified foreign financial assets with both amounts. The test is more than the stated amount, not equal to it. The higher outside-the-United-States thresholds apply only when your tax home is in a foreign country and you meet an IRS presence-abroad test.
Specified-individual thresholds. Filing applies when total value is more than either amount in the applicable row.
Residence and filing status | Last day | Any time during year |
|---|---|---|
United States: unmarried or married filing separately | $50,000 | $75,000 |
United States: married filing jointly | $100,000 | $150,000 |
Qualifying outside U.S.: unmarried or married filing separately | $200,000 | $300,000 |
Qualifying outside U.S.: married filing jointly | $400,000 | $600,000 |
A specified domestic entity has a threshold of more than $50,000 on the last day of its tax year or more than $75,000 at any time during the year. That amount does not itself determine whether an entity is a specified domestic entity.
Value, joint ownership, and foreign currency
For threshold testing, an asset is generally valued at fair market value. Determine a foreign-currency maximum in that currency, then convert it to U.S. dollars using the exchange rate on the last day of the tax year, even if you sold the asset or closed the account earlier. Use zero when an asset’s maximum value is less than zero. You may rely on an account statement’s conversion rate if the maintaining institution issues the statement at least annually.
Joint assets use different threshold and reporting rules
Do not confuse the threshold calculation with the value entered on the form. If spouses are specified individuals filing separate returns, each uses one-half of a jointly owned asset’s value to test the threshold, but each reports the entire maximum value on a separate Form 8938. Spouses filing jointly report a jointly owned asset once, at its entire maximum value, on their combined form. Other joint owners generally include the entire value.
Choose the right reporting path before completing the lines
Specified foreign financial assets include accounts maintained by foreign financial institutions and certain investment assets not held in a financial account, including foreign stock or securities, an interest in a foreign entity, and certain instruments or contracts with a non-U.S. issuer or counterparty. A financial account maintained by a U.S. payer, such as a domestic financial institution, is not a specified foreign financial asset under these instructions.
Choose Part V or Part VI
Reportable item
deposit or custodial account → 2
other qualifying item → 3
Part V account record
summarize → 4
Part VI asset record
summarize → 5
Part I summary
Part II summary
Use Part V for each foreign deposit or custodial account. Use Part VI for other reportable financial accounts and specified foreign financial assets not held in a financial account. If you have an interest in a financial account that holds specified foreign financial assets, report the account; do not separately report the assets inside it.
When Part IV replaces duplicate asset detail
If you timely reported an asset for the same tax year on Form 3520, 3520-A, 5471, 8621, or 8865, Part IV records the number of applicable forms filed instead of repeating qualifying asset details. When all assets are reported that way, a specified individual completes the name and TIN at the top and Part IV only. When only some are reported elsewhere, complete Part IV and report the remaining assets in Parts V or VI.
Apply the correct Part IV threshold rule
Part IV does not have the same threshold effect for every filer. A specified individual includes the value of Part IV assets when testing the threshold. A specified domestic entity excludes the value of assets reported on a listed Part IV form.
Complete the header and page 1 summaries
Lines 1–4 and additional statements
Enter the calendar or tax year at the top. Enter names and the TIN as shown on the annual return: a specified individual uses the first TIN shown on the income tax return, while a specified domestic entity uses its EIN. On line 3, choose the filer type. A specified individual checks box 3a and skips line 4. A partnership or corporation enters the closely holding specified individual’s name and TIN on line 4; a trust enters the current-beneficiary specified person’s name and TIN.
Attach additional copies of page 2 when more than one Part V account, Part VI asset, or additional Part VI issuer or counterparty requires separate information. Check the header box and state the number of additional statements. A paper filer with more than one person to list on line 4 attaches a statement with each required name and TIN.
Parts I–IV: summaries, tax items, and exceptions
Complete each applicable Part V or Part VI record first, including attached page 2 copies.
Part I: lines 5–6 count and total Part V deposit accounts; lines 7–8 count and total custodial accounts. Line 9 asks whether any of those accounts closed during the year.
Part II: line 10 counts all Part VI accounts and assets, line 11 totals their maximum values, and line 12 asks about openings, closures, acquisitions, or dispositions.
Part III identifies applicable interest, dividends, royalties, other income, gains or losses, deductions, and credits attributable to reported assets, along with the form, schedule, and line where the item was reported.
Part IV, lines 15–19, records the number of Forms 3520, 3520-A, 5471, 8621, and 8865 filed; it does not repeat excepted asset details.
Part V: report each foreign deposit or custodial account
Lines 20–23: identify the account and its maximum value
Complete one Part V record for each reported account. On line 20, choose deposit or custodial; on line 21, enter the account number or other specific designation. Line 22 permits every applicable status box: opened, closed, jointly owned with spouse, or no tax item reported in Part III for that asset. Line 23 is the maximum value during the tax year, not simply the closing balance. The account type determines whether it feeds Part I deposit totals on lines 5–6 or custodial totals on lines 7–8.
Lines 24–28: conversion and institution details
If you used a foreign-currency exchange rate to convert the account value to U.S. dollars, answer Yes on line 24. Complete line 25 with the currency, rate, and the source if the Treasury Bureau of the Fiscal Service did not provide the rate. Otherwise answer No and proceed to line 26. Enter the maintaining institution’s name and address on lines 26–28. The GIIN is optional; the IRS says no penalty applies for leaving it blank or entering it incorrectly.
Part V currency conversion
Use the last-day-of-tax-year exchange rate even if the account closed earlier. In most cases, use the Treasury Bureau of the Fiscal Service rate for purchasing U.S. dollars. If no Treasury rate is available, use another publicly available rate and disclose its source.
Part VI: report other foreign assets and finish the filing
Lines 29–34: describe, value, and convert the asset
For each Part VI account or asset, describe it on line 29 and provide its identifying number or designation on line 30. Line 31 records applicable acquisition or disposition dates, joint ownership with a spouse, and no-tax-item status. Enter “Various” if acquisitions or dispositions occurred on different dates during the year. On line 32, select the maximum-value band; enter an exact maximum only when it is more than $200,000. These detailed values feed Part II line 11.
If foreign-currency conversion was used, answer Yes on line 33 and complete line 34 with the currency, exchange rate, and the required source when no Treasury rate was provided. A No answer leads to the applicable identity branch.
Line 35 or line 36: select the correct identity branch
Choose Part VI line 35 or line 36
Line 29 asset
stock of or interest in entity → 2
all other assets → 3
Line 35: foreign entity
Line 36: issuer or counterparty
more than one → 4
Additional line 36 statements
Use lines 35a–35e only for stock of, or an interest in, a foreign entity. Enter the entity name, optional GIIN, entity type, and address. Otherwise use lines 36a–36e: identify the issuer or counterparty, state which role applies, select its type and whether it is a U.S. or foreign person, and enter its address. If an asset has more than one issuer or counterparty, attach separate line 36 information for each additional one and mark and count the added statements at the top of page 1.
Reconcile every Part V record to Part I and every Part VI record to Part II.
Complete Part III for applicable tax items and Part IV for qualifying timely filed forms.
Mark and count all additional page 2 statements, then attach the form to the annual or amended return by that return’s due date, including extensions.
Failure-to-file consequence
A required filer who does not timely file a complete and correct Form 8938 may be subject to a $10,000 penalty. After an IRS notice, an additional $10,000 for each 30-day period, or part of a period, may apply after 90 days, up to $50,000 additional.
Sources and how this page was made
This guide explains the official sources listed below in plain language. Displayed amounts, limits, percentages, and timing rules come from that material.
Source revision reflected in this guide: Form: 2021; Instructions: 2021.