Common reasons expats request a review
- A first U.S. return after moving abroad or learning that citizenship-based filing may apply.
- Foreign pensions, retirement arrangements, insurance products, or investment accounts.
- Joint accounts with a non-U.S. spouse or family member.
- A local business, partnership, corporation, or trust interest.
- Earlier returns that did not include Form 8938 or related foreign-asset information.
Higher thresholds are conditional
The Form 8938 instructions provide higher thresholds for qualifying taxpayers living abroad. The taxpayer must meet the applicable tax-home and bona fide residence or physical presence conditions. Merely holding a foreign address is not enough.
Local and U.S. treatment may differ
A product’s familiar local label does not determine its U.S. tax classification. Preparation may require plan statements, account terms, entity records, and country-specific facts. Local-law advice is outside scope unless a qualified local professional is separately involved.
Form 8938 is only one possible international reporting form. The engagement letter should identify exactly which returns and forms are included.