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Foreign account reporting

FATCA compliance checklist: what goes on Form 8938

Form 8938 thresholds by filing status and residence, the specified foreign financial assets that are reportable (and the ones that are not), UK pensions, ISAs and company shares, and when the form is due.

Published 19 June 2026 · Updated 7 November 2026 · 2 min read

Form 8938 is filed with your Form 1040 when the total value of your specified foreign financial assets passes the threshold for your filing status and where you live. It is separate from, and in addition to, the FBAR.

Thresholds

SituationLast day of yearAny time in year
Living abroad, single or married filing separately> US$200,000> US$300,000
Living abroad, married filing jointly> US$400,000> US$600,000
Living in the US, single or separately> US$50,000> US$75,000
Living in the US, jointly> US$100,000> US$150,000

"Living abroad" means your tax home is in a foreign country and you meet the bona fide residence or physical presence test.

Reportable: financial accounts (also on the FBAR)

  • UK current, savings and deposit accounts, including cash ISAs
  • UK investment and brokerage accounts, including stocks-and-shares ISAs
  • Money market and fund accounts
  • Fintech and e-money accounts held with UK entities

Reportable: other specified assets (Form 8938 only)

  • Shares or securities issued by a foreign company held directly, not through an account
  • Interests in foreign entities: UK limited company shares, partnership and LLP interests
  • Interests in foreign trusts and estates
  • UK pension entitlements, with the valuation basis stated
  • Foreign-issued life insurance or annuity contracts with a cash value
  • Financial instruments or contracts with a foreign counterparty

Not reported on Form 8938

  • UK real estate held directly in your own name
  • Physical gold, silver and other tangible assets held personally
  • UK state pension and similar social-security-type entitlements
  • Assets already reported on Forms 3520, 5471, 8621 or 8865 (you tick the box and give the count instead of repeating them)

Deadline

Form 8938 is part of your tax return, so it follows the return: 15 April, automatically 15 June for people abroad, and 15 October with an extension. The FBAR has the same dates but is filed separately with FinCEN.

When to get help

UK pensions, ISAs full of funds, UK company shares and interests in family trusts are the items that need judgement rather than a checklist. We review every foreign asset when preparing the return and record how each one was treated.

Written by the US UK Expat Tax advisory team. Last reviewed 7 November 2026 · Figures relate to the 2025 (filed 2026) tax year unless stated.

General information, not personal tax advice. Rules and thresholds change; we confirm the position for your facts before any work.

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