Yes, these are considered Foreign Assets to report. These may need to be reported on an FBAR if each account is considered a segregated foreign account. A segregated foreign account is one is created by the employer and funded by the employer, the employee, or both (i.e., a defined contribution plan). If your retirement account has this arrangement, then each account must be reported on the FBAR, if these exceeds $10K at any time during the year.
in addition, if the total balance of your combined accounts exceed $100,000 on the last day of the tax year or more than $150,000 at any time during the tax year, you must file a 8938.
If your foreign pension is placed in a Foreign Trust, these need to be reported on a 3520. You may contact the institution where your retirement funds are held to find out if these are placed in a trust in IRC sections 671-679. Read more about that here. If your pension is a SIPP plan, then it is considered a foreign trust. I mention this here as an example but there may be other pension plans that are defined in IRC sections 671-679.
You can retroactively file an FBAR here. Here is a link that gives you detailed instructions how to file.
if you need to file forms 8938 from past years, you will need to amend your previous years tax returns to include 8938.
As far as the 3520, there does not seem to be a provision in filing for previous years. These are due every year by March 15 but you can ask for an extension until September 15. This is a gray area because we do not know if your pensions fall within IRC sections 671-679. You may wish to consult with a paid preparer that could further assist you in this matter.
As far as how many years to go back, there is no limit for these types of filings. as an FYI, Turbo Tax does not prepare 3520's. They do prepare FBAR's starting in Tax Year 2024 and 8938 for 2024 and in previous tax years.
If you have filed with Turbo Tax in previous years, reach out to us and we can tell you how to amend your previous tax returns if a 8938 is required. let us know if you are using Turbo Tax Online or the software version.
Form 3520 and Instructions
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