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The parts are not in the order you fill them. Parts I and II summarize what you enter in Parts V and VI, so you work the form from the bottom up: build Parts V and VI first, then count them.
Part III cross checks your return. It lists the income from each asset and the schedule that reported it.
The value is the peak. Maximum value during the year at the year end rate, even for an account closed in March.
Part IV removes the detail, not the form. You leave assets on a timely filed listed return out of Parts V and VI, but you still file Form 8938.
Two rules to check before filing:
You attach it to the annual return, and it is due when that return is due, extensions included.
A second account means a second Part V block, on an additional statement.
Both of those are why a two page form becomes six pages for anyone with more than a couple of accounts.
Six parts, and only two of them repeat. The IRS sets out the order it uses, which is not the order you work in.
The IRS converted the form and its instructions from an annual revision to continuous use, so it updates them only when something changes. A year stamped edition is a superseded file.
The six parts of Form 8938.
How many, and what they totalled
How many, and what they totalled
Interest, dividends, gains, deductions, and which schedule carries each
3520, 3520-A, 5471, 8621, 8865. Count of forms only
Institution, number, maximum value, currency
Description, issuer or counterparty, value range
If every asset sits on one of the Part IV forms, you file name, TIN and Part IV. Nothing else on the form.
Part III lists the interest, dividends, royalties, other income, gains, deductions and credits attributable to the assets you listed, and the schedule or form that reported each one. It is a cross check, and an inconsistent return shows up there.
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The Form 8938 instructions require the highest value each asset reached during the year, not the balance on the last day. You may rely on periodic account statements unless you have reason to know they miss the peak.
Take one euro account, single filer, living in the US, at a year end rate of 0.90 euro to the dollar.
The value to report is the peak.
| Point in the year | Balance | In dollars | Test |
|---|---|---|---|
| December 31 | 45,000 euro | 50,000 dollars | Last day test, more than 50,000: not met |
| June peak | 72,000 euro | 80,000 dollars | Any time test, more than 75,000: met, so the form is due |
The rule is the same for assets. Foreign shares worth 60,000 dollars on the last day, with readily available price information showing a high of 94,000 dollars during the year, are reported at 94,000.
The Form 8938 instructions require the Treasury reporting rate for purchasing US dollars. Where Treasury publishes no rate for your currency, use another publicly available rate and disclose the source on the form. You enter that disclosure on line 25 in Part V and line 34 in Part VI.
Three details to get right:
The IRS does not reject a return for a wrong conversion. The form then shows a number no statement supports, and that is the kind of error the IRS raises in correspondence two years later.
You leave anything already reported on a timely filed Form 3520, 3520-A, 5471, 8621 or 8865 out of Parts V and VI; the Form 8938 instructions call this duplicative reporting. You do not describe it again. You enter how many of each of those forms you filed, and that is the entire Part IV entry.
Two conditions:
For a specified individual whose assets are on those timely filed forms in full, the filing reduces to your name, taxpayer identification number and Part IV. That is the difference between a twenty block form and a four line one.
If the form was filed last year, by you or by someone else, have it checked before the same figures roll forward. Values, rates and Part IV entries are copied into the next return, and a wrong maximum value repeats until someone corrects it.
Send the statements and we tell you which parts you need before any work is quoted. Handled by a CPA or an Enrolled Agent.
Two parts repeat, and the Form 8938 instructions set the fields for each block.
Part V, once per deposit or custodial account:
Deposit or custodial, which the institution can confirm if the statement does not say
Account number, or the identifying detail where the account has no number
Opened, closed or jointly held with a spouse, as check boxes, plus a box for an account that produced no tax item
Maximum value, then the currency, the rate and the source of the rate where you converted
Institution name and address, plus the GIIN where you have been given one
Part VI, once per other asset:
A description that identifies it: for a share holding, the class and issuer
Acquisition or disposal dates during the year, entered as various where there were several
A value range up to a maximum of 200,000 dollars; above that you enter the exact figure
Either the foreign entity block or the issuer and counterparty block, depending on what the asset is
The GIIN should not hold up a filing. If your institution did not give you one, there is no penalty for leaving it blank and none for entering the wrong one. The maximum value line is different.
Send statements for each foreign account and holding, plus last year’s return if the form was filed before.
We check Part IV first, because we can leave anything on another timely filed information return out of Parts V and VI.
We set each maximum value from the statements and convert at the year end rate, recording the source.
We build one Part V or Part VI block per item, on additional statements where there is more than one.
We complete Part III against the return itself, so the income shown matches the schedules that report it.
We attach the form to the return and file, and you keep the value schedule for next year.
We work by video and phone with clients in all 50 states, and after step one there is little for you to do.
Pricing runs per account and per year, not per return. These are the factors that set a quote, and you get the fixed number before the work starts.
People are using AI or attempting to use AI to complete their tax planning or their tax returns, and a few tax advisors said that they put a client’s tax situation in four different models and got four different answers, and some of them hugely incorrect.
I have used Dimov CPA for my past two years of taxes. They helped me complete my tax returns after being overseas for 30 years and were very helpful with my international investments. Xintian specifically was excellent with communication and advice.
Our team includes CPAs and Enrolled Agents who work on individual returns, business taxes and tax planning. Tell us what you need help with when you get in touch.
You can work through the Form 8938 instructions yourself. It costs an evening, then a second evening when the additional statements and the peak values do not agree. If that is where you are, hand it over and get the return filed.
General rules only, not advice on your situation. Which parts you complete turns on facts we have not seen, so speak to a CPA or an Enrolled Agent before filing.
