Form 8938 (2015) Foreign Asset Reporting Guide Checklist

Form 8938 Checklist: 2015 Tax Year

Purpose

Form 8938 requires U.S. citizens, residents, and certain nonresidents to report specified foreign financial assets, including foreign bank accounts, foreign financial accounts, stock or securities issued by non-U.S. entities, interests in foreign corporations, and other foreign holdings.

For 2015, filers must use the established asset valuation ranges ($0–$50,000, $50,001–$100,000, $100,001–$150,000, $150,001–$200,000, or exact value if exceeding $200,000) and identify whether assets are jointly owned with a spouse or closed during the year. This reporting complements your income tax return and ensures compliance with Section 6038D reporting requirements for domestic entities and foreign assets.

Required Filing Steps

1. Verify filing requirement: Confirm the aggregate maximum value of specified foreign financial assets on the last day of the tax year or any prior date exceeds the applicable threshold for your filing status and residence. Review the 2015 instructions for threshold tables based on married filing jointly, married filing separately, or single/head of household status to determine your reporting requirements.
2. Gather foreign bank accounts and foreign financial account records: Collect maximum values, account numbers or designations, dates of opening/closing, financial institution names and addresses, and currency information for all foreign deposit accounts (including savings, checking, and money market) and custodial accounts held during 2015. Document foreign bank accounts separately from other asset types.
3. Gather other foreign assets, including foreign stocks: Collect descriptions, identifying numbers, acquisition and disposition dates (if applicable in 2015), maximum values, issuer/counterparty names and addresses, and entity type classifications. This includes stock or securities issued by foreign entities, interests in foreign corporations, debt instruments, partnership interests, and other foreign holdings not maintained in financial accounts.
4. Classify each asset and complete Parts I and II summaries: Count and report maximum values for deposit accounts, custodial accounts, and all other foreign assets in the summary sections. Note whether any foreign financial accounts were closed, or assets were acquired or sold during 2015. Separate foreign bank accounts from stock or securities for proper classification.
5. Complete the Part III tax item attribution: Report interest, dividends, royalties, other income, gains/losses, deductions, and credits attributable to each specified foreign financial asset category. Cross-reference the exact form (e.g., income tax return Form 1040, Schedule C, Schedule D) and the line number where each item was reported. This ensures proper coordination between Form 8938 and your income tax return.
6. Determine excepted assets and complete Part IV for reporting requirements: If you filed Form 3520 (reporting certain foreign trusts), Form 3520-A (foreign trust annual information), Form 5471 (information return for U.S. persons with respect to certain foreign corporations), Form 8621 (passive foreign investment company reporting), or Form 8865 (return for U.S. persons with respect to certain foreign partnerships) in 2015 reporting specified foreign financial assets, you must still include the value of those assets when determining whether you meet the filing threshold under Section 6038D.

However, these excepted assets do not need to be reported again in the detailed sections (Part V or Part VI). Instead, complete Part IV of Form 8938 to identify how many of each form you filed, thereby satisfying reporting requirements without duplication. If all of your specified foreign financial assets are reported on these other forms, you only need to complete the header information and Part IV of Form 8938.

7. Complete Part V for each deposit or custodial account: Enter account type, number/designation, opening/closing status, maximum value, foreign currency used (if applicable), and exchange rate source (U.S. Treasury Department or other). Identify the financial institution name, mailing address, city, country, and postal code. Do not include in Part V any foreign bank accounts already reported on excepted forms listed in Part IV.
8. Complete Part VI for each other foreign asset: Describe the asset type (including foreign stocks held outside financial accounts, interests in foreign corporations, or other stock or securities). Enter the identifying number, note acquisition/disposition dates if applicable to 2015, select the maximum value range, or enter the exact amount if exceeding $200,000. Identify the source of the foreign currency conversion and exchange rate, if applicable.

Provide the foreign entity or issuer/counterparty name, address, entity type classification (corporation, partnership, trust, estate, or individual), and indicate whether the entity is a U.S. person or foreign person. Do not include in Part VI any assets already reported on the exception forms listed in Part IV.

9. Attach continuation statements: If more than one foreign bank account, foreign financial account, or other foreign asset (such as multiple foreign stocks or interests in foreign corporations) requires detailed reporting in Parts V and VI, prepare separate continuation statements with identical Part V and Part VI detail for each additional asset on pages matching the 2015 form continuation format.
10. Sign and date the return to which Form 8938 is attached: Form 8938 attaches to your 2015 income tax return, Form 1040 (or applicable U.S. tax return for domestic entities, such as Form 1120 for corporations or Form 1065 for partnerships). Execute your return with your signature and date; ensure the return preparer (if applicable) signs and dates, as well.
11. Assemble in the correct order: Place Form 8938 and any continuation statements immediately after your 2015 Form 1040 and required schedules (Schedule A, B, C, D, etc.) but before other forms and attachments, per Attachment Sequence No. 175.
12. File your 2015 tax return (electronically or by mail): Form 8938 can be filed either electronically or on paper with your income tax return. If you e-file your 2015 Form 1040, Form 8938 is submitted electronically with your return. If you have a paper file, mail the complete return package (Form 1040, Form 8938, continuation statements, and all supporting schedules) to the address specified in the 2015 Form 1040 mailing instructions.

2015 Year-Specific Updates & Regulatory Changes

Jointly Owned Foreign Assets Reporting on Form 8938

Married taxpayers who jointly own specified foreign financial assets, such as foreign stocks or interests in foreign corporations, may report those assets on a single combined Form 8938 if the applicable filing threshold is met. In these cases, the full value of each jointly owned asset is reported once on the form rather than being split between spouses. This approach simplifies reporting while still meeting the disclosure requirements under Section 6038D.

Part III Tax Items Attribution Requirements

Part III of Form 8938 requires taxpayers to specifically identify where income, gains, losses, deductions, or credits related to foreign assets are reported on their income tax return. Filers must cross-reference the exact form and line number used on the 2015 income tax return, such as Schedule A, Schedule B, Schedule C, Schedule D, or Form 1040. This requirement ensures consistency and traceability between Form 8938 and the taxpayer’s reported tax items.

Part IV Excepted Asset Reporting Clarification

Beginning in 2015, taxpayers who satisfy Form 8938 reporting requirements by completing Part IV for assets already reported on other international information returns must ensure proper coordination between forms. Assets reported on Form 3520, Form 3520-A, Form 5471 (for foreign corporations), Form 8621, or Form 8865 may be excluded from duplicate reporting on Form 8938, provided Part IV is completed.

Each of the corresponding forms must include a newly added checkbox indicating that the asset is counted in Part IV of Form 8938. This process prevents duplicative reporting while maintaining compliance with Section 6038D disclosure rules for domestic entities and foreign corporations.

Need Help With IRS Issues? 

If you're facing IRS issues and need expert guidance beyond this checklist, we're here to help with licensed tax professionals. 

We offer: 

• Wage garnishment and bank levy release 
• Tax lien removal and credit protection 
• Offer in Compromise and installment agreements 
• Unfiled tax return preparation 
• IRS notice response and representation

‍

Get professional help today: (888) 260-9441

20+ years experience • Same-day reviews available

This checklist is for educational purposes only and does not constitute tax or legal advice. Always review official IRS instructions and consult a qualified professional for guidance.