How many continuation statements can I attach to Form 8938?

The Instructions for Form 8938 do not set a maximum. You attach as many additional copies of page 2 as you need, one for each Part V account or Part VI asset beyond the first, check the box at the top of page 1 and enter the number of additional statements. UK-resident Americans with private bank, broker, platform and pension relationships commonly attach ten or more. What matters is that the page count, the Part I and Part II totals and the entries all agree.

Do I list every fund inside my UK ISA or platform account on Form 8938?

No. Under the Form 8938 instructions, if you have an interest in a financial account you do not report the individual assets held in that account. A stocks and shares ISA or a platform general investment account is one Part V custodial account entry at its maximum value for the year, however many funds it holds. UK funds that are passive foreign investment companies may need their own Form 8621, which is a separate filing.

My UK bank already reports my accounts to HMRC under FATCA. Do I still need Form 8938?

Yes, if you are over your threshold. Under the International Tax Compliance Regulations 2015, UK financial institutions report accounts held by US citizens to HMRC, but that institutional reporting does not replace your own Form 8938 obligation to the IRS. For Americans living in the UK who meet the presence abroad test, Form 8938 applies above $200,000 at year-end or $300,000 at any time for single filers, and $400,000 or $600,000 for joint filers.

Is my UK State Pension or workplace pension reported on Form 8938?

The UK State Pension is not reported, because the instructions exclude rights to the foreign equivalent of US social security. A UK workplace or personal pension plan interest is different: the instructions direct you to report your interest in a foreign pension plan in Part VI, without listing the assets inside the plan. If you do not know its value and received no distributions, the instructions provide a fallback valuation rule, including a value of zero in some cases.

Should the values on my Form 8938 match my FBAR?

For accounts that appear on both, they usually should. Both start from each account's maximum value in its own currency and convert at a year-end rate, normally the US Treasury rate for 31 December for calendar-year filers. Form 8938 also lets you rely on the rate shown in an annual account statement, so small differences can be legitimate, but they should be documented. The two account lists will still differ, because some accounts belong on only one of the filings.

Can I e-file a Form 8938 with many continuation statements?

A Form 8938 attached to an ordinary return is normally filed electronically with it, with the tax software generating the additional Part V and Part VI entries. The exception UK-resident catch-up filers need to know is the Streamlined Foreign Offshore Procedures: the IRS page says the submission must be sent in paper form and electronic submissions will not be accepted, so the continuation pages are printed and attached in order behind Form 8938.

Form 8938 Continuation Statements for Many UK Accounts

Form 8938 continuation statements are the additional copies of page 2 of Form 8938 that you attach when you have more than one foreign account or asset to report in Part V or Part VI. The IRS does not publish a separate continuation form: the instructions tell you to copy page 2, attach the copies, check the box at the top of page 1 and enter the number of additional statements. For a UK-resident American with a private bank, two or three brokers, investment platforms, ISAs, pensions and direct company shareholdings, those attached pages are usually most of the filing, and they are where most of the errors hide.

In the returns we prepare for high-net-worth Americans in London and across the UK, a Form 8938 with fifteen, twenty or more line items is normal. This guide covers how to structure that list: what each Part V and Part VI entry has to contain, what drops out through the Part IV exceptions, how the list should reconcile with the FBAR, how to handle accounts opened, closed or held jointly with a non-US spouse, and how to present a numbered schedule that an IRS examiner, or your own reviewer, can follow line by line. The rules below come from the current Form 8938 (Rev. November 2021) and the Instructions for Form 8938 (Rev. 11-2021) at https://www.irs.gov/instructions/i8938.

What are Form 8938 continuation statements?

A Form 8938 continuation statement is an extra copy of page 2 of the form, carrying one more Part V account and, where needed, one more Part VI asset, attached behind the main form. Page 2 of the current revision has room for exactly one Part V entry (a foreign deposit or custodial account) and one Part VI entry (an other foreign asset). The form says so at the head of each part: if you have more than one account to report in Part V, or more than one asset in Part VI, you attach a separate statement for each additional one. You can see that wording on the form itself at https://www.irs.gov/pub/irs-pdf/f8938.pdf, where page 1 also carries the box 'If you have attached additional statements, check here' and a space for the number of additional statements.

The Specific Instructions section of the Instructions for Form 8938 sets out the mechanics under the heading Additional statements: make additional copies of page 2, attach them to the form, check the box at the top of page 1, and enter the number of additional statements in the space provided. The same instruction applies where a single Part VI asset has more than one issuer or counterparty; line 36 carries a note telling you to attach a separate statement with the same information for each additional issuer or counterparty.

One quirk is worth knowing. The IRS page Basic questions and answers on Form 8938 at https://www.irs.gov/businesses/corporations/basic-questions-and-answers-on-form-8938 answers the continuation-sheet question by telling filers to copy as many blank Parts I and II as they need. On the current revision, Parts I and II are summary parts; the account-by-account detail sits in Parts V and VI on page 2. Where the Q&A wording and the current instructions differ, we follow the current form and its instructions, and we copy page 2.

Continuation statements are not the Section 6038D continuation penalty

Search results often mix up two unrelated uses of the word continuation. A continuation statement is a page you attach. A continuation penalty is the additional amount the IRS can charge under section 6038D when a required Form 8938 is still not filed after the IRS has sent a notice. Under the current instructions, the base failure-to-file penalty is $10,000, and if a complete and correct form is not filed within 90 days after the IRS mails a notice, an additional $10,000 can apply for each 30-day period or part of one, up to a maximum additional penalty of $50,000. Our separate article on Form 8938 penalties and Section 6038D continuation charges covers that exposure. This article is only about the paperwork: how to lay out a long list of assets so that the form you file is complete and correct in the first place.

Which UK assets go in Part V and which go in Part VI?

Part V is for foreign deposit and custodial accounts. Part VI is for everything else that is reportable: financial accounts that are not deposit or custodial accounts, and specified foreign financial assets held outside any account. Getting the split right matters on a long list because Part I totals only the Part V accounts and Part II totals only the Part VI items, so an asset placed in the wrong part breaks both summaries. In the UK files we prepare, the split usually looks like this.

Part V, deposit accounts: sterling and currency current accounts, savings and notice accounts, cash ISAs, and private bank deposit accounts.
Part V, custodial accounts: stockbroker general investment accounts, stocks and shares ISAs and general investment accounts held on investment platforms, and private bank custody or discretionary portfolio accounts.
Part VI, other foreign assets: interests in UK workplace or personal pension plans, which the instructions direct to Part VI without listing the assets inside the plan; shares in UK companies held directly on a share register rather than through a broker; loan notes or bonds issued by UK persons and held outside an account; and interests in foreign partnerships or private funds held directly.
Not on Form 8938 at all: the UK State Pension, because the instructions exclude rights to the foreign equivalent of US social security; accounts maintained by a US payer, which in general includes a foreign branch or foreign subsidiary of a US financial institution; UK property held directly; and physical cash, precious metals or personal property.

Two instruction rules keep the list shorter than clients expect, and one keeps it longer. First, if you have an interest in a financial account, you do not report the individual securities held in that account; a platform account holding thirty funds is one Part V entry, not thirty. Second, a direct shareholding reported on a timely Form 5471 or Form 8621 drops into the Part IV count, discussed below. Against that, a caution box in the instructions confirms that retirement and pension accounts and certain savings accounts that an intergovernmental agreement excludes from the financial institution's own reporting must still be reported on Form 8938. The UK agreement does not shrink your list.

What does each Part V account entry need?

Every Part V entry, whether on the main page 2 or on a continuation statement, carries the same fields, lines 20 to 28. On a twenty-account schedule, missing fields on the later pages are the most common defect we find when we review returns prepared elsewhere.

Line 20: whether the account is a deposit or a custodial account. This drives which Part I lines it totals into: lines 5 and 6 for deposit accounts, lines 7 and 8 for custodial accounts.
Line 21: the account number, or other specific identifying information if there is no account number.
Line 22: four check boxes for account opened during the tax year, account closed during the tax year, account jointly owned with spouse, and no tax item reported in Part III with respect to this asset.
Line 23: the maximum value of the account during the tax year, in US dollars, as an actual figure.
Line 24: whether you used a foreign currency exchange rate to convert the value into dollars.
Line 25: if line 24 is yes, the currency the account is maintained in, the exchange rate used, and the source of the rate if it did not come from the US Treasury Bureau of the Fiscal Service.
Lines 26a and 26b: the name of the financial institution and, optionally, its Global Intermediary Identification Number (GIIN).
Lines 27 and 28: the mailing address of the institution, including city, country and postal code.

The GIIN is marked optional on the form. The instructions say you will not be penalised for leaving it blank or entering the wrong one, and that completing it may reduce the need for the IRS to contact you. If the bank has not given you its GIIN, the IRS FATCA Foreign Financial Institution List Search and Download Tool at https://www.irs.gov/businesses/corporations/fatca-foreign-financial-institution-list-search-and-download-tool can be used to look it up. On a long list we complete it wherever it can be matched reliably, because it ties each entry to the institution that holds the account.

What does each Part VI asset entry need?

Part VI, lines 29 to 36, asks for a description of the asset (including the class or issue for shares or securities), an identifying number, dates of acquisition or disposal during the year, the joint-with-spouse and no-tax-item check boxes, the maximum value, the currency conversion details, and then details of the issuer. Line 35 applies where the asset is stock of, or an interest in, a foreign entity: its name, optional GIIN, entity type and mailing address. Line 36 applies where the asset is not stock of or an interest in a foreign entity, such as a loan note or a contract: the name of the issuer or counterparty, its type, whether it is a US or foreign person, and its address.

Line 32 is where Part VI differs visibly from Part V. Instead of an exact figure, you tick a band: $0 to $50,000, $50,001 to $100,000, $100,001 to $150,000 or $150,001 to $200,000. Only above $200,000 do you enter the actual maximum value on line 32e. On a long schedule, that means Part II line 11 cannot simply be footed from the page 2 copies; you need the underlying values in your working papers to support the total you enter. Where the same asset was acquired or disposed of on several dates in the year, the line 31 instructions say to enter Various rather than listing every date.

How does Part IV shorten a long Form 8938?

Part IV, Excepted Specified Foreign Financial Assets, is a count, not a list. If you report a specified foreign financial asset on another information return that you timely file for the same tax year, you do not repeat it on Form 8938; instead you enter how many of those forms you filed. On the current revision, lines 15 to 19 cover five forms: Form 3520, Form 3520-A, Form 5471, Form 8621 and Form 8865. Some older guides still list Form 8891, which does not appear in Part IV of the current form.

For a UK relationship footprint, the relevant ones are usually Form 5471 for a UK company in which the client holds a reportable stake, Form 8865 for an interest in a UK partnership where that form is required, and Form 8621 for UK funds treated as passive foreign investment companies. Three practical points follow.

The exception depends on the other form being timely filed. On a catch-up filing, the Part IV count and the late forms need to travel together in the same package.
Assets reported on those forms still count toward your Form 8938 threshold. The instructions are explicit that a specified individual includes their value when testing whether the threshold is met.
If every one of your specified foreign financial assets is covered by those forms, the instructions tell you to enter your name and TIN and complete Part IV only. That is rare for a UK resident, because bank and broker accounts almost always sit outside those forms.

Where UK funds are held inside a platform or broker account, we still list the account in Part V. The Form 8621 deals with the fund shares; the account itself is the financial account that Form 8938 asks about.

Form 8938 thresholds for Americans living in the UK

Thresholds are a supporting fact here, not the subject, but they decide whether any of this applies. Under the instructions, a taxpayer who meets the presence abroad test (a US citizen who is a bona fide resident of a foreign country for an uninterrupted period that includes an entire tax year, or a US citizen or resident present in a foreign country for at least 330 full days in a 12-month period ending in the tax year) files Form 8938 if the total value of specified foreign financial assets is more than $200,000 on the last day of the tax year or more than $300,000 at any time during the year. For married couples filing jointly the figures are $400,000 and $600,000, and married filing separately uses the $200,000 and $300,000 figures. The IRS comparison page at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements sets the same numbers beside the FBAR's $10,000 aggregate test. If you are not required to file an income tax return, you are not required to file Form 8938.

For a client with a private banking relationship, the threshold question is usually settled by the first two accounts. The work is in the list.

How do you reconcile Form 8938 with your FBAR account list?

The FBAR and Form 8938 overlap but do not match, and on a long relationship footprint the differences are predictable. Filing Form 8938 does not relieve you of the FBAR, and the FBAR is filed separately through FinCEN's BSA E-Filing System rather than with your return, as explained at https://www.fincen.gov/report-foreign-bank-and-financial-accounts. Using the IRS comparison table, we build the reconciliation in three buckets.

On both: UK deposit and custodial accounts in your own name, including ISAs and broker accounts, foreign mutual funds, and cash-value life insurance or annuity contracts.
On the FBAR only: accounts over which you have signature authority but no financial interest, such as your employer's or your company's accounts; accounts you reach through an entity you own more than 50% of; and accounts at a foreign branch of a US financial institution, such as a London branch of a US bank, which Form 8938 treats as maintained by a US payer.
On Form 8938 only: UK shares and securities held directly outside an account, interests in foreign partnerships, and foreign hedge fund and private equity fund interests.

The FBAR also has a shortcut that Form 8938 does not. Under FinCEN's FBAR line item filing instructions, a filer with a financial interest in 25 or more foreign financial accounts answers yes to that question, enters the number of accounts and leaves the separate and joint account sections blank, while keeping full records that must be produced if FinCEN or the IRS asks for them. Form 8938 has no equivalent. A client with thirty UK accounts may file a short FBAR but will still have thirty Part V entries on Form 8938. Our article on the FBAR 25 or more accounts rule covers that side.

Values are where reconciliation usually fails. Both regimes start from the maximum value of each account in its own currency during the year, and both convert at a year-end rate: the FBAR at the Treasury rate for the last day of the calendar year, and Form 8938 at the Treasury Bureau of the Fiscal Service rate on the last day of the tax year. The Form 8938 instructions add two refinements: you use the year-end rate even for an account closed earlier in the year, and you may instead rely on the conversion rate shown in a financial account statement issued at least annually by the institution. For a calendar-year filer who takes the same sterling maximum from the same statement and converts at the same Treasury rate, the dollar figure for a given account should be identical on both filings. When a reviewer sees one account at $412,000 on the FBAR and $436,000 on Form 8938, the first question is which filing used a different month's balance or a different rate. We therefore carry one master value per account into both filings, with the statement date and the rate recorded beside it.

How to build a numbered set of Form 8938 continuation statements

A long Form 8938 is easier to prepare, review and defend when every item carries a permanent reference number and the filed pages follow a fixed order. Nothing in the instructions prescribes a numbering system; this is the working-paper convention we use, and it maps one-to-one onto the filed pages. The asset register behind the form holds these columns.

Reference: V-01, V-02 and so on for Part V accounts, and VI-01, VI-02 for Part VI assets. A number is never reused, so when V-07 closes it is retired rather than handed to a new account.
Order: deposit accounts first, then custodial accounts, grouped by institution; then Part VI assets grouped by type, such as pensions, direct shareholdings and loan notes.
Institution name, address and GIIN, exactly as they will appear on lines 26 to 28 or line 35.
Account number or identifier, recorded in full in the working papers.
Currency, maximum value in that currency, and the statement or date the maximum was taken from.
Exchange rate used and its source, with a note if an annual statement rate replaced the Treasury rate.
US dollar maximum value, and for Part VI the band that goes on line 32.
Flags: opened, closed, acquired or disposed (with dates), jointly owned with spouse, and whether a Part III tax item was reported.
Cross-references: the FBAR entry for the same account, and the return schedule and line where its income was reported.

Control totals close the loop. The number of deposit rows and their total value must equal Part I lines 5 and 6; the custodial rows must equal lines 7 and 8; the Part VI rows must equal Part II lines 10 and 11; and the number of attached page 2 copies must equal the number entered beside the box at the top of page 1. We also put the taxpayer's name and TIN at the top of every continuation page, so that a page separated from the return during processing can be matched back. That is our practice rather than a line-item requirement, but it costs nothing.

Because each copy of page 2 holds one Part V and one Part VI entry, a list of twelve accounts and three other assets needs eleven additional copies, with the three Part VI items riding on the main page and the first two copies. Tax software may paginate differently. Whatever convention it uses, the count on page 1 must match what is actually attached.

How do you handle accounts opened or closed mid-year on a long list?

Mid-year movement is routine for UK clients: a fixed-term deposit matures, a new ISA is opened at the start of the UK tax year in April, a portfolio moves after a change of broker. Each movement touches four places on Form 8938.

Line 22a or 22b on the Part V entry for the account concerned (opened or closed during the tax year), or lines 31a and 31b with dates for a Part VI asset, using Various where there are several dates.
Part I line 9 (were any foreign deposit or custodial accounts closed during the tax year) and Part II line 12 (were any foreign assets acquired or sold during the tax year).
The maximum value for the part of the year the account existed, converted at the rate for the last day of the tax year even though the account closed earlier.
Your threshold test, because an account closed in March still counts toward the at-any-time test even though it contributes nothing to the year-end figure.

A closed account is reported for the year in which it closes and then drops off the next year's schedule. A transfer between UK brokers is, for Form 8938 purposes, a closure at one institution and an opening at another, and both entries belong on that year's schedule, each at its own maximum value. The combined Part I total can therefore look larger than the client's real wealth, because the same portfolio was the maximum in two accounts at different times. That is how the form works; we note the transfer in the working papers so a reviewer is not surprised.

How do you report joint accounts with a non-US spouse?

Many UK-resident Americans are married to a UK national who is not a US person. That spouse is not a specified individual and does not file Form 8938, and the US spouse often files married filing separately. The instructions contain two different rules, and both matter on a long list.

For the threshold, where the joint owner is a spouse who is not a specified individual, each joint owner includes the entire value of the jointly owned asset. The half-value rule in the instructions applies only where both spouses are specified individuals filing separate returns. Example 11 in the instructions works through exactly this case for a couple living abroad.

For the entry itself, you report the maximum value of the entire jointly held account, regardless of the value of your separate interest. We tick line 22c (account jointly owned with spouse) on a Part V joint account, and line 31c on a Part VI asset, so that the reviewer can see at a glance why a household account is shown at full value on one spouse's form. On the FBAR, FinCEN's instructions have the filer identify the principal joint owner of a jointly owned account, who is the spouse where the spouse has an interest in it.

Worked scenario: a London relationship footprint on one Form 8938

The figures below are an illustration, not a client's return. We assume an exchange rate of 0.80 pounds per US dollar purely to keep the arithmetic readable; on a real return the rate is the published Treasury rate for the last day of the tax year, or an annual statement rate where the instructions allow it.

Daniel is a US citizen who has lived in London for nine years and meets the presence abroad test. His wife is a UK national and not a US person, so he files married filing separately, and his threshold is more than $200,000 at year-end or more than $300,000 at any time. He owns a UK trading company for which he timely files Form 5471. His relationship footprint produces eleven Part V accounts and three Part VI assets.

Deposit accounts (6): private bank sterling current account, maximum 310,000 pounds ($387,500); private bank US dollar deposit, maximum $95,000 with no conversion, so line 24 is No; cash ISA at a building society, 20,000 pounds ($25,000); joint current account with his wife, 48,000 pounds ($60,000, entire value, line 22c ticked); easy-access savings account closed in March, 150,000 pounds ($187,500, line 22b ticked, converted at the year-end rate); challenger bank account, 12,000 pounds ($15,000). Part I lines 5 and 6: 6 accounts, $770,000.
Custodial accounts (5): private bank discretionary portfolio, 2,400,000 pounds ($3,000,000); broker A general investment account, 640,000 pounds ($800,000); broker B account opened in June, 180,000 pounds ($225,000, line 22a ticked); platform stocks and shares ISA, 95,000 pounds ($118,750); platform general investment account, 60,000 pounds ($75,000). Part I lines 7 and 8: 5 accounts, $4,218,750. Line 9 is Yes because of the closed savings account.
Other foreign assets (3): interest in a workplace defined contribution pension, 410,000 pounds ($512,500, above $200,000 so entered on line 32e); ordinary shares in a UK start-up held directly, 40,000 pounds ($50,000, first band); loan note issued by a UK private company, 100,000 pounds ($125,000, third band). Part II lines 10 and 11: 3 assets, $687,500.
Part IV: line 17, Number of Forms 5471, is 1. The shares in his trading company are not listed in Part V or Part VI but still count toward his threshold.

Eleven Part V entries and three Part VI entries mean the main page 2 plus ten additional copies of page 2. The three Part VI assets sit on the main page and the first two copies, and the remaining eight copies carry Part V entries only. The box at the top of page 1 is checked and 10 is entered as the number of additional statements. Each page carries its reference numbers, V-01 to V-11 and VI-01 to VI-03, in register order.

His FBAR lists thirteen accounts: the eleven Part V accounts, plus his company's UK bank account (signature authority and majority ownership, so FBAR only) and a deposit account at the London branch of a US bank (a US payer for Form 8938 purposes, but reportable on the FBAR). The directly held start-up shares and the loan note appear only on Form 8938, and the pension's FBAR treatment is a separate analysis. Every one of the eleven shared accounts carries the same dollar maximum on both filings, and the reconciliation sheet shows why the counts differ: 11 in Part V, 13 on the FBAR, with each difference explained by reference number.

E-file or paper: what changes with many continuation statements?

Form 8938 is not a standalone filing. The instructions say not to send it to the IRS unless it is attached to an annual return or an amended return, and the form carries attachment sequence number 938, which fixes its place among the attachments behind your Form 1040.

On an ordinary return filed electronically, the continuation pages are generated by the software rather than photocopied. Professional packages typically let you enter each account as a separate record and then produce the additional Part V and Part VI entries automatically, carrying Part III and Part IV only once and checking the page 1 box. The review points are the same as on paper: the count, the totals, and no entry with blank required fields. We make no general claim about any product's limits; on very long lists we check the generated output page by page before transmission.

Paper is unavoidable in one important case. The IRS page for the Streamlined Foreign Offshore Procedures at https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states states that the submission must be sent in paper form and that electronic submissions will not be accepted, and it asks for Streamlined Foreign Offshore to be written in red at the top of the first page of each return and at the top of each information return. On a Form 8938 with ten continuation pages, we mark the first page of the form and keep the attached page 2 copies in reference order directly behind it.

Using the schedule in a Streamlined Foreign Offshore or catch-up filing

Long Form 8938 schedules often reach us inside a catch-up. Under the Streamlined Foreign Offshore Procedures, an eligible taxpayer resident outside the United States files returns for each of the most recent three years for which the due date has passed, together with all required information returns (the IRS page names Forms 3520, 5471 and 8938 as examples), files any delinquent FBARs for the most recent six years, and signs Form 14653 certifying that the failures resulted from non-willful conduct. The non-residency test requires, in at least one of the three years, no US abode and physical presence outside the United States for at least 330 full days.

A catch-up is where the numbered schedule pays for itself. Three years of Form 8938 and six years of FBARs are prepared from one register, so V-04 is the same broker account in every year it existed, with a year-by-year maximum value and rate. Openings and closures line up across years, the FBAR-only and Form 8938-only items are explained once, and the IRS sees a consistent picture. Late FBARs in a Streamlined package are filed through BSA E-Filing, selecting Other as the reason for filing late and entering Streamlined Filing Compliance Procedures in the explanation, as the IRS page instructs. The IRS has withdrawn its former delinquent FBAR submission procedures page, so do not rely on older guides that describe that route as current.

Accuracy on the first filing matters because the statute of limitations stays open. If Form 8938 is not filed, or a required asset is left off, the instructions say the limitations period for that year may remain open for all or part of the return until three years after the date on which Form 8938 is filed. A missing account on continuation page seven is not a harmless omission.

Does UK FATCA reporting change what goes on your US list?

UK-resident clients sometimes ask why they must list accounts the IRS may already know about. Under the UK-US agreement to implement FATCA, signed on 12 September 2012 and given effect through regulations now contained in the International Tax Compliance Regulations 2015, UK financial institutions must identify and report information to HMRC on financial accounts held by US citizens and entities. HMRC's International Exchange of Information Manual describes this at https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim400040. That institutional reporting sits alongside your own obligation; it does not replace it. It is, however, one more reason for the list to be complete and for the institution names and account numbers on your continuation pages to match the way the bank itself identifies the account.

Common errors on long Form 8938 schedules

The page 1 box checked but the number of additional statements left blank, or a number that does not match the pages attached.
Part I and Part II totals that do not foot to the entries in Parts V and VI, often because a closed account was left out of the total but kept on a continuation page.
Each fund inside a platform or ISA account listed as a separate asset instead of reporting the account once.
A pension interest placed in Part V as if it were a custodial account, when the instructions direct pension plan interests to Part VI.
Different exchange rates or different maximum balances for the same account on the FBAR and on Form 8938.
Only a half share shown for an account held jointly with a non-US spouse.
The UK State Pension left on the list, or a London branch of a US bank carried onto Form 8938 because it appeared on the FBAR.
A Part IV exception claimed for a Form 5471 or Form 8621 that was not in fact timely filed.

Final checks before you sign

Before a long Form 8938 goes out, we confirm that every UK account and asset in the register has a reference number, a part, a supported maximum value, a rate and its source, and a complete set of flags; that Parts I, II and IV reconcile to the pages; that the page 1 count matches the attachments; and that the FBAR reconciliation explains every difference. Done that way, twenty accounts on continuation statements are no harder for an examiner to read than two. If your UK relationship footprint has outgrown the form, our team prepares Form 8938, FBARs and Streamlined packages for UK-resident Americans as part of full US and UK return preparation.