Form 8938 Foreign Financial Assets Checklist – 2024
Tax Year
Overview of Form 8938 for the 2024 Tax Year
Form 8938 requires certain U.S. citizens and resident aliens to report specified foreign financial assets when total values exceed applicable thresholds. The form and its instructions operate under a continuous-use framework, meaning the IRS updates them as needed rather than issuing annual redesigns. You must always rely on the version in effect for the tax year you are filing.
Form 8938 applies only to specified foreign financial assets, not all foreign property or income.
Proper compliance requires understanding who must file, which assets count, how thresholds apply, and how the form integrates with your annual income tax return. Accurate reporting depends on careful asset identification, valuation, aggregation, and return assembly.
Who Must File Form 8938 for 2024
You must file Form 8938 if you meet two conditions during the 2024 tax year. You must be a
U.S. citizen or a resident alien for any part of the year, or otherwise qualify as a specified individual under the instructions. You must also hold specified foreign financial assets that exceed the applicable reporting threshold.
Thresholds depend on both filing status and residence. You evaluate thresholds using asset values on December 31, 2024, and the highest value reached at any time during 2024.
Exceeding either threshold independently triggers the filing requirement, even if the excess occurred for only one day.
Applicable Reporting Thresholds Based on Filing Status
and Residence
Taxpayers residing in the United States use lower thresholds than those living abroad. Filing status controls which dollar limits apply, and you must select your filing status based on your marital status as of December 31, 2024. Each threshold applies to the combined value of all specified foreign financial assets.
For taxpayers residing in the United States, the thresholds are as follows
- Single filers and heads of household must file if assets exceed $50,000 on December
31, 2024, or $75,000 at any time during 2024.
- Married filing jointly taxpayers must file if assets exceed $100,000 on December 31,
2024, or $150,000 at any time during 2024.
- Married filing separately taxpayers must file if assets exceed $50,000 on December 31,
2024, or $75,000 at any time during 2024.
Taxpayers living abroad apply higher thresholds
- Single filers and heads of household abroad must file if assets exceed $200,000 on
December 31, 2024, or $300,000 at any time during 2024.
- Married filing jointly taxpayers abroad must file if assets exceed $400,000 on December
31, 2024, or $600,000 at any time during 2024.
- Married filing separately taxpayers abroad must file if assets exceed $200,000 on
December 31, 2024, or $300,000 at any time during 2024.
Specified Foreign Financial Assets for 2024
Specified foreign financial assets include a defined group of financial interests held outside the
United States. These assets include foreign financial accounts, foreign stocks and securities, interests in foreign partnerships, stock of foreign corporations, and foreign insurance contracts with cash surrender values.
Certain assets remain excluded from Form 8938 reporting. Excluded items include foreign real property held directly, U.S. securities held through U.S. financial institutions, and foreign businesses operated as branches. Solely owned foreign entities reported on Schedule C or
Schedule F are not reported separately when the business itself constitutes the asset.
Ownership structure affects reporting obligations. Jointly owned assets and community property assets require careful treatment, and a joint owner generally holds an interest in the entire asset, subject to special spousal reporting rules.
Filing Status and Threshold Application Steps
- Step 1: Determine Your 2024 Filing Status
- Identify your filing status for the 2024 tax year based on your marital status as of December 31,
- 2024. Filing status determines which reporting thresholds apply to your foreign assets. You must use the same filing status selected on your Form 1040.
- Step 2: Confirm Your 2024 Residency Status
- Determine whether you qualify as residing in the United States or abroad for threshold purposes. U.S. citizens and resident aliens generally use the same thresholds unless they maintain a tax home outside the United States. Temporary absences do not change residency status for this determination.
- Step 3: Evaluate Married Filing Separately Status
- Confirm whether you file married filing separately for 2024. Married filing separately taxpayers apply individual thresholds regardless of a spouse’s assets or filing status. You report only assets in which you hold an interest and do not aggregate spouse-owned assets.
- Step 4: Apply the Correct Threshold Test
- Apply both the December 31, 2024, threshold and the anytime-during-2024 threshold. You must file Form 8938 if either test is exceeded. Each test stands independently, and exceeding one triggers the filing requirement.
- Step 5: Determine Asset Values in U.S. Dollars
- Determine the value of each specified foreign financial asset in U.S. dollars as of December 31,
- 2024. You must use a reasonable exchange rate for that date. In most cases, you first identify the maximum foreign currency value during the year, then convert using the year-end exchange rate.
- Step 6: Report Assets in Part I of Form 8938
- Report each specified foreign financial asset in Part I of Form 8938. You must list the asset type, country of location, maximum value for 2024, and value as of December 31, 2024. You must also select the correct asset category code for each item.
- Step 7: Aggregate Asset Values for Threshold Comparison
- Add all December 31, 2024, asset values together, then separately add all maximum values during 2024. Compare each aggregate total to the applicable threshold. Aggregation includes assets held under any name and with any institution.
- Step 8: Evaluate FBAR Filing Obligations
- Determine whether you must also file FinCEN Form 114, also known as the FBAR. FBAR reporting applies when foreign financial accounts exceed $10,000 in aggregate at any time during 2024. Form 8938 and FBAR serve different purposes and use different definitions.
- Some assets appear on both forms, while others appear on only one. FBAR covers foreign financial accounts, while Form 8938 covers accounts and additional financial assets. Filing one form does not satisfy the requirement to file the other.
- Step 9: Attach Form 8938 to Your 2024 Tax Return
- Complete Form 8938 using the version applicable to the 2024 tax year. Attach it to your Form
- 1040, Form 1040-SR, or Form 1040-NR. You must file Form 8938 with your annual income tax return and not as a standalone submission.
- Step 10: Sign and Verify Return Accuracy
- Form 8938 does not include a separate signature line. Your signature on the income tax return covers the attached form. If filing jointly, both spouses must sign the return. If you file an amended return, attach an amended Form 8938.
- Step 11: Assemble the Return in Proper OrderAssemble your return in the correct order before submission. Place Form 8938 immediately after the primary income tax form and before schedules and other attachments when filing on paper. Proper ordering supports accurate processing.
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- Step 12: File by the Applicable Deadline
- File Form 8938 with your complete tax return by the same due date. For the 2024 tax year, the deadline is April 15, 2025, unless extended. An extension of the return deadline automatically extends the Form 8938 filing deadline.
- Key 2024 Instructional Clarifications
- The 2024 instructions confirm that exceeding the threshold on any single day during the year triggers the anytime reporting test. Asset values do not need to remain above the threshold for a full reporting period. Temporary spikes still require filing.
- The instructions also clarify treatment of American Depositary Receipts, asset category codes, and married filing separately reporting rules. Penalties may not apply when a failure to disclose results from reasonable cause and not willful neglect.
- If you’re missing tax documents or want to ensure the numbers you enter match IRS records, we can help.
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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.
