Foreign Asset Reporting
Foreign Asset and Information Reporting
Information reporting is separate from paying tax. Many U.S. taxpayers with foreign accounts, entities, or interests owe no additional tax and still have annual disclosure obligations. Identifying them early is straightforward; discovering them late is more complicated.
Interests that commonly require reporting
- Foreign financial accounts
- FBAR (FinCEN Form 114)
- Form 8938 (specified foreign financial assets)
- Foreign corporations
- Foreign partnerships
- Foreign disregarded entities
- Foreign trusts
- Foreign gifts and inheritances
- Foreign pensions
- Foreign mutual funds and PFICs
- Ownership, signature authority, and indirect interests
Thresholds and duplication
FBAR and Form 8938 overlap but are not the same: they have different thresholds, different definitions of a reportable asset, different filing mechanics, and different agencies. An account can be reportable on one, both, or neither. We inventory the full set of accounts and interests once, then map them to the correct forms.
If filings were missed
Penalties for missed international information returns can be substantial, but the system also provides corrective procedures, and reasonable-cause relief may be available depending on the facts. Voluntary, well-documented correction is generally a better position than waiting for a notice. We assess the facts and explain the realistic options — without predicting an outcome.
The forms that apply depend on each client's facts and circumstances.
Frequently asked questions
Does reporting mean I owe more tax?
Often not. Information reporting and tax liability are separate. Many disclosures are informational and result in no additional tax.
Do small accounts count?
Thresholds are based on aggregate values, not per-account balances, and the aggregation rules differ between forms. Small accounts often matter when combined.
My foreign retirement account — is it reportable?
It depends on the plan's legal form, your interest in it, and sometimes treaty provisions. Foreign pensions are one of the most fact-dependent areas and are worth reviewing specifically.
Request a Foreign Reporting Review
FBAR, Form 8938, and the information returns that apply to foreign accounts, entities, trusts, and gifts.