Reporting Non-Financial Assets

Do you own foreign real estate or digital wallets? Understanding the line between FBAR and Form 8938 is critical for your compliance strategy. We're here to clarify the complexities.

Explore Regulations

Non-Financial Asset Reporting Regulations

Navigating FATCA, FinCEN, and the evolving digital landscape.

Foreign Real Estate Nuances

Commonly, clients ask if their family villa in Tuscany needs to be on an FBAR. The short answer? Usually not. But once that asset is held within a foreign corporation or earns rental income, the reporting landscape shifts dramatically. We help you distinguish between personal use property and reportable financial interests.

*Always consult with our team for entity-held assets.

Virtual Currencies & Wallets

How do regulatory bodies view your cold storage? Current FinCEN guidance is evolving. While the FBAR traditionally covers bank accounts, digital wallets that act as custodial accounts often fall under FATCA Form 8938 requirements. You don't want to leave your crypto portfolio exposed to penalties.

FBAR vs. Form 8938

It's not an "either/or" situation. Many taxpayers must file both. While FBAR (FinCEN 114) focuses on accounts, Form 8938 (FATCA) encompasses a broader range of "specified foreign financial assets." Our guidance ensures you're not double-counting or, worse, under-reporting.

Client Experiences

"Andrew Macedo made sense of my offshore crypto mess. Truly efficient!"

Golf Elfie

Why did we choose Andrew Macedo? Because their team actually answers the phone and explains the 17-page regulations in plain English. We had three foreign properties and a complex inheritance, and they handled it all.

Gwendora Fratella, Real Estate Lead

"The peace of mind knowing my non-financial assets are disclosed correctly is worth every penny."

Ramsay E.

Frequently Asked Questions

Unsure about your specific assets? Check these common scenarios or reach out to us directly at info@e-filetoday.com.

Compliance specialist reviewing documents

Generally, real estate held in your individual name does not require an FBAR filing. However, if that real estate is held via a foreign entity (like an LLC or S.A.), you may have a reporting obligation for the entity's bank accounts. We suggest a review if your holdings are indirect.

Think of FBAR as account-based and FATCA as wider asset-based. Even if you've reported a bank account on FBAR, you might still need to include it (and other assets like stock or partnership interests) on Form 8938 if you exceed the filing thresholds (e.g., $50,000 for unmarried residents).

Inheritance triggers specific reporting requirements, often under Form 3520. While the asset itself (like jewelry or art) isn't financial, the transfer of ownership from a foreign estate to a U.S. person is highly regulated. Don't wait until the next tax season to look into this.