Once you've confirmed you're a specified person over the reporting threshold, completing Form 8938 is a methodical exercise. The form is filed with your Form 1040 (or the relevant business return) — there's no separate submission system, unlike the FBAR. If you e-file your return, Form 8938 is transmitted along with it.
Before you start, gather these
Year-end statements for every foreign account, the highest balance each account reached during the year, the name and address of each foreign institution, account numbers, and the details of any foreign stock, entity interest, or instrument you hold outside an account. Having these in front of you turns the form into data entry.
The form, step by step
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Complete the identifying information
At the top, enter your name and taxpayer identification number exactly as they appear on your return, and indicate the type of filer (individual or a specified domestic entity). If this is a continuation statement because you have many assets, you'll check that box.
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Part I — Foreign deposit and custodial accounts
Summarize the number of deposit accounts and custodial accounts, their total maximum value, and whether any were opened or closed during the year. This is the summary layer for your Bucket 1 accounts.
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Part II — Other foreign assets
Summarize the number of "other" specified foreign financial assets (foreign stock held directly, entity interests, foreign instruments), their total maximum value, and whether any were acquired or disposed of during the year.
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Part III — Summary of tax items
Report the income items (interest, dividends, gains, deductions, credits) attributable to your specified foreign financial assets, and identify which schedule or form of your return each item appears on. This is how the IRS cross-checks the disclosure against the income you actually reported.
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Part IV — Excepted assets (avoid duplicate reporting)
If an asset is already reported on Form 3520, 5471, 8621, or 8865, you don't detail it again here — instead you note how many of each of those forms you filed. This keeps you from reporting the same foreign corporation or trust twice.
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Parts V & VI — Detailed asset information
Provide the account-by-account and asset-by-asset detail: institution names and addresses, account numbers, maximum values during the year, the exchange rate and source used, and joint-ownership information. Part V is for financial accounts; Part VI is for other assets.
Valuing each asset
You report the maximum fair market value of each asset during the year, converted to U.S. dollars. Use the U.S. Treasury Bureau of the Fiscal Service year-end exchange rate for the conversion (or another publicly available rate, consistently applied, if Treasury doesn't publish one for that currency). For accounts, a periodic statement is usually enough to establish value. See Valuing Foreign Assets for Form 8938 for the details.
You can generally rely on account statements
You don't have to obtain an independent appraisal of an account's value. The instructions let you rely on periodic financial account statements to figure the maximum value, as long as those statements fairly reflect the account's value during the year.
Attach it and keep your records
Attach the completed Form 8938 to your income tax return and file by your return's due date (including extensions). Keep copies of the statements and exchange-rate sources you used to support the figures, in case the IRS asks. There's no separate confirmation number the way there is with the FBAR — your proof is the filed return itself.
Filing Form 8938 does not replace the FBAR
If you also meet the FBAR's separate $10,000 threshold, you still have to file FinCEN Form 114 through the BSA E-Filing System. The two are independent obligations. See Form 8938 vs. FBAR.
If you missed a prior year
If you realize you should have filed Form 8938 in a past year, don't panic-file without understanding your options first. Depending on the facts, amended returns or one of the IRS's established compliance procedures may be appropriate — and the right path is fact-specific. This is a good moment to talk to a qualified professional; see our Deadlines & Penalties guide for context.