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New Member

Is a 100K deposit acct in Citibank Philippines a foreign financial asset? Or is the bank a Foreign branch of a U.S. fin'l institution ? Do I need to file a Form 8938?

If you have stock holdings handled by a foreign entity brokerage, is that a foreign financial asset or an other foreign financial asset?
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New Member

Is a 100K deposit acct in Citibank Philippines a foreign financial asset? Or is the bank a Foreign branch of a U.S. fin'l institution ? Do I need to file a Form 8938?

The answers to your questions about foreign financial reporting and accounts follow.

If you are a United States citizen, and assuming that you own a bank account or maintain other financial assets in a foreign country (that includes the Philippines as well as elsewhere), then there are certain foreign financial account reporting requirements that you must meet, or at least test, annually, in addition to filing a primary tax return (Form 1040, etc.)

In fact, there are two separate foreign account disclosure forms that may be required; each also has different reporting rules.  One is known as IRS Form 8938, and can be attached to the relevant yearly Form 1040 tax return.  The other is FinCen Form 114, which can only be filed via the internet.  The following Internal Revenue Service webpage describes them in some detail, and provides their dollar value reporting levels:


Form 8938 is included in TurboTax; FinCen Form 114 is not, and you may need to access that reporting webpage separately, if your foreign financial assets total over the limit(s).  Note that you can get to the FinCen reporting internet site through the above IRS link.

If a financial account, such as a depository bank account, is held through a foreign branch or foreign affiliate of a U.S.-based financial institution, then the foreign account is not a specified foreign financial asset, and it is not required to be reported on Form 8938.

However, the test for FinCen Form 114 is different.  In that case the relevant factor is that the account is physically located in another country.  So, in your instance, if the dollar amount of your Philippines bank account (with Citibank) exceeds the relevant reporting threshold (see the rules at the IRS site link above), then you would need to file FinCen Form 114 for it.  However, because it is a deposit with a US-based bank, albeit at their Philippines branch, you don't have to disclose it on IRS Form 8938.

With respect to the other part of your question, in all cases and for both reporting forms, stock held by a foreign brokerage firm, outside of the United States, is a "specified foreign financial account" and needs to be disclosed . . . if the value of the account exceeds the filing thresholds.

Confusing?  Yes, it most certainly is; but those are the current tax rules with which everyone has to comply.

Thank you for asking about this.

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