Do I have to file Form 8938 for foreign assets? Confused about thresholds
I've been trying to figure out if I need to file Form 8938 (Statement of Specified Foreign Financial Assets) with my taxes this year, but I'm getting confused by the different threshold requirements. Looking at the IRS website and reading through the thresholds, I can't tell if I'm actually required to report or not because some of the requirements seem to contradict each other. Do I have to file a Form 8938 if I hold a foreign investment account worth about $65,000? I'm unmarried and live in the US. Some parts of the instructions make it sound like I need to file, but other sections suggest I might be under the threshold. The IRS guidance mentions different amounts for different situations and I'm not sure which applies to me. Has anyone dealt with Form 8938 filing requirements before who can clarify this? I really don't want to mess up and face penalties for not filing something I was supposed to.
22 comments


Chloe Zhang
The filing requirements for Form 8938 depend on your filing status, where you live, and the total value of your foreign financial assets. For a single taxpayer living in the US (which appears to be your situation), you're required to file Form 8938 if the total value of your specified foreign financial assets exceeds $50,000 on the last day of the tax year OR exceeds $75,000 at any time during the tax year. With your foreign investment account worth about $65,000, you would need to file Form 8938 if that was the value on the last day of the tax year, since it exceeds the $50,000 threshold. However, if the account fluctuated and was worth $65,000 at some point during the year but dropped below $50,000 by year-end, you'd still need to file if it ever exceeded $75,000 during the year. Keep in mind that the Form 8938 requirement is separate from the FBAR (FinCEN Form 114) filing requirement, which has a $10,000 threshold. You might need to file both forms depending on your situation.
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Brandon Parker
•Thanks for the info! I've heard about the FBAR too but wasn't sure about the difference. So if my account was worth $65k in August but dropped to $48k by December 31, would I NOT need to file Form 8938? And does the $75k threshold mean the highest value it reached at any point in the year?
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Chloe Zhang
•Based on your example, if your account was worth $65,000 in August but dropped to $48,000 by December 31, you would NOT need to file Form 8938 since you're below the $50,000 end-of-year threshold and never exceeded the $75,000 at-any-time-during-the-year threshold. Yes, the $75,000 threshold refers to the highest value your foreign assets reached at any point during the tax year. So if your account fluctuated throughout the year but never went above $75,000, and ended below $50,000, you wouldn't need to file Form 8938 (though you may still need to file the FBAR if the account exceeded $10,000).
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Adriana Cohn
After struggling with these exact Form 8938 filing requirements last year, I discovered taxr.ai (https://taxr.ai) which totally saved me. I uploaded my foreign account statements, and it analyzed everything to tell me exactly which forms I needed to file. The tool showed me that I actually had multiple reportable foreign assets that I hadn't even considered (like that small pension account from when I worked abroad), and calculated my total foreign assets correctly. It even explained which threshold applied to my situation. The best part was that it flagged potential FATCA reporting issues that I would have completely missed. Definitely worth checking out if you're trying to figure out if you need to file Form 8938.
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Jace Caspullo
•How accurate is it with calculating the maximum value during the year? My accounts are in different currencies, and I'm never sure what exchange rate to use or when to calculate the peak value.
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Melody Miles
•Hmm, sounds interesting but I'm skeptical. Couldn't you just look at your statements yourself and add up the amounts? Why use another service for something simple like that?
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Adriana Cohn
•It automatically tracks the highest balance throughout the year and applies the correct exchange rates for the specific dates needed - you just upload statements and it identifies the peak values by date. No need to manually figure out which day had the highest value or which exchange rate to use. The real value came when I realized I had overlooked certain assets that qualified as "specified foreign financial assets" under Form 8938 but not under FBAR. The tool flagged my foreign pension and an investment account that I didn't think counted. These technical distinctions are easy to miss when you're doing it yourself.
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Melody Miles
I wanted to follow up about that taxr.ai service I was skeptical about earlier. I tried it and I have to admit it was actually really helpful. I discovered I had been calculating my foreign asset values incorrectly for years! The tool showed me that some of my foreign mutual funds were actually PFICs (Passive Foreign Investment Companies) that required additional reporting on Form 8621, which I had no idea about. It also confirmed that I needed to file Form 8938 because I had exceeded the threshold when counting ALL my foreign assets together, not just my main account. I was able to correct my previous returns before any issues arose. Definitely saved me from potential headaches with the IRS.
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Nathaniel Mikhaylov
If you're still confused about Form 8938 requirements, I'd recommend calling the IRS directly. But good luck getting through! I spent HOURS on hold trying to get clarification about my foreign reporting requirements last month. Finally found this service called Claimyr (https://claimyr.com) that got me connected to an actual IRS agent in less than 20 minutes. They have this system that navigates the IRS phone tree and waits on hold for you, then calls you when an agent picks up. You can see how it works here: https://youtu.be/_kiP6q8DX5c The IRS agent I spoke with gave me specific guidance on my Form 8938 situation and confirmed I needed to file based on my circumstances. Apparently the threshold calculations are even more complex than what's in the basic instructions.
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Eva St. Cyr
•Wait, how does this actually work? Does it just call the IRS for you? I'm confused how this helps with the hold times.
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Kristian Bishop
•Yeah right. No way this actually works. I've called the IRS dozens of times and ALWAYS wait at least an hour. No "service" can magically get you through faster than anyone else. Sounds like a scam to me.
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Nathaniel Mikhaylov
•It uses an automated system that dials in to the IRS, navigates through all the prompts and menu options for you, and then stays on hold in your place. When an actual human IRS agent finally picks up, the service calls your phone and connects you directly to that agent. You don't have to listen to hold music or stay by your phone. I was skeptical too. But it's not about "cutting the line" - you still wait the same total time an IRS agent would take to answer, but you don't have to be the one actively waiting on hold. I was able to go about my day, and then my phone rang when an agent was ready. Saved me from having to sit there listening to the hold music for what turned out to be 47 minutes.
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Kristian Bishop
OK I have to admit I was completely wrong about that Claimyr service. After being stuck on this Form 8938 question for weeks and getting nowhere, I decided to try it yesterday out of desperation. It actually worked exactly as described. I put in my number, and about 35 minutes later I got a call connecting me directly to an IRS agent. I didn't have to wait on hold at all. The agent was super helpful and confirmed that in my specific situation, I DO need to file Form 8938 because I have multiple types of foreign assets that collectively exceed the threshold, even though no single account does. Apparently, there are some complicated aggregation rules I was missing. Would have never figured this out from just reading the instructions.
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Kaitlyn Otto
Don't forget to also look at whether you need to file FinCEN Form 114 (FBAR) in addition to Form 8938. The thresholds are different! FBAR is required if your foreign accounts together exceed $10,000 at any time during the year, which is much lower than the Form 8938 thresholds. I got hit with a penalty for missing the FBAR even though I filed Form 8938 correctly. The systems don't talk to each other, so filing one doesn't mean you're covered for the other.
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Axel Far
•Is the FBAR filed with your tax return too? Or is it filed somewhere else? The whole foreign account reporting system is so confusing.
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Kaitlyn Otto
•The FBAR (FinCEN Form 114) is NOT filed with your tax return. It's filed separately with the Financial Crimes Enforcement Network, which is part of the Treasury Department but separate from the IRS. You file it electronically through the BSA E-Filing System (https://bsaefiling.fincen.treas.gov/). The deadline is actually April 15, but they automatically extend it to October 15 every year - you don't need to request the extension. It's totally separate from your tax return, which is why many people miss it even when they get their taxes right.
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Jasmine Hernandez
Don't feel bad about being confused - Form 8938 requirements are super complicated. I'm a US expat and had to figure this out when I moved abroad. Here's a cheat sheet I made for myself: Single living in US: - $50k on last day of year OR - $75k at any time during year Married filing jointly in US: - $100k on last day of year OR - $150k at any time during year Living abroad (filed extension or qualify for foreign earned income exclusion): - Single: $200k on last day of year OR $300k any time - Married filing jointly: $400k on last day OR $600k any time Hope this helps someone!
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Luis Johnson
•This cheat sheet is so helpful! Does "living abroad" mean physically living outside the US, or is there some technical definition for tax purposes?
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Angelina Farar
For tax purposes, "living abroad" typically means you qualify as a bona fide resident of a foreign country or meet the physical presence test (330 days outside the US in a 12-month period). It's not just about where you happen to be on a particular day. The key is that you need to have filed for an extension to file your tax return OR qualify for the foreign earned income exclusion to use the higher thresholds. Just being physically outside the US temporarily doesn't automatically qualify you for the higher Form 8938 thresholds. If you're unsure about your status, it's worth checking IRS Publication 54 (Tax Guide for U.S. Citizens and Resident Aliens Abroad) or consulting with a tax professional who specializes in expat tax issues.
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Keisha Thompson
•Thanks for clarifying that! I was wondering about this exact scenario. I travel frequently for work but still maintain my US residence, so I wasn't sure if those business trips abroad would affect my Form 8938 thresholds. Good to know it's based on actual tax residence status rather than just physical location. The Publication 54 reference is really helpful - I'll check that out to make sure I'm using the right thresholds for my situation.
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Dmitri Volkov
Great question and thanks to everyone for the detailed responses! I went through a similar situation last year and want to add a few points that might help: 1. Make sure you're counting ALL specified foreign financial assets, not just bank accounts. This includes foreign stocks, bonds, mutual funds, and even interests in foreign partnerships or trusts. 2. The valuation date matters a lot. You need to track the maximum value during the year AND the end-of-year value. I recommend keeping quarterly statements or screenshots of account balances throughout the year. 3. Currency conversion can be tricky - you must use the Treasury's published exchange rates for the specific dates, not just any random exchange rate you find online. One thing I learned the hard way: even if you don't meet the Form 8938 threshold, you might still need to file other forms like 3520 or 5471 depending on what types of foreign assets you have. The reporting requirements can overlap but they're all separate obligations. Also, penalties for not filing Form 8938 when required are steep - $10,000 initially, then $10,000 for each 30-day period of continued non-filing up to $60,000. Definitely better to file when in doubt!
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Michael Green
•This is incredibly helpful, especially the point about tracking maximum values throughout the year! I had no idea about the Treasury exchange rates requirement - I've been using whatever rate my bank showed me. Do you know where exactly to find these official Treasury rates? And that penalty structure is terrifying - $60,000 maximum penalty definitely makes it worth being extra careful about compliance. Your point about other forms like 3520 and 5471 is also eye-opening. I thought I only had to worry about Form 8938 and FBAR, but it sounds like there might be even more reporting requirements depending on the specific types of foreign investments. This is getting pretty complex - might be time to consult a professional!
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