Is allocated gold stored in a UK vault reportable on the FBAR?

There is no published FinCEN ruling on allocated storage. The IRM says directly held metal is not a financial account, but a reportable relationship may exist where a foreign agency holds metal on deposit, insures it or acts as agent, or can dispose of it on instruction. Allocated services with insurance, online selling and cash settlement often meet that description, so many preparers disclose them rather than rely on an exclusion.

Is an unallocated gold or silver account with a UK bank an FBAR account?

Generally yes. An unallocated account gives you a claim against the provider for a quantity of pooled metal, much like a deposit. That fits the regulation's other financial account category for persons accepting deposits as a financial agency, and a UK bank metal account may also be a bank account. If your foreign accounts together exceeded 10,000 dollars at any time in the year, it belongs on the FBAR.

Do I report physical gold held in the UK on Form 8938?

Not if it is held directly. The IRS states that directly held precious metals such as gold, and directly held tangible assets, are not specified foreign financial assets. However, gold certificates issued by a foreign person may be reportable, and a financial account at a foreign financial institution is reportable. Unallocated metal and platform cash balances therefore need the same structural analysis you apply for the FBAR.

Are UK Britannia and Sovereign coin gains taxable in the US?

Yes. HMRC treats post-1837 Sovereigns and Britannias as sterling currency, exempt from UK Capital Gains Tax. The US has no equivalent rule. A US citizen or resident must report the gain, and long-term gains on coins and metal are collectibles gains taxed at a maximum 28% rate. Because no UK tax was paid, there is no UK tax to credit against the US liability.

Is gold bullion taxed differently from bars in the UK?

In the UK the distinction is between sterling currency coins and everything else. HMRC's Capital Gains Manual confirms post-1837 Sovereigns and Britannias are exempt as sterling currency, while non-sterling currency coins such as Krugerrands are chargeable assets. Gold and silver bars are also chargeable. For US purposes all of these are collectibles, so the UK exemption does not change the US answer.

How do I fix a missed FBAR for a UK precious metals custody account?

If all income was reported and only the FBAR was missed, file the late FBARs through FinCEN's BSA E-Filing System with a reason for late filing. If metal sale gains or other foreign income were also omitted, UK residents meeting the 330-day non-residency test usually use the Streamlined Foreign Offshore Procedures: three years of returns, six years of FBARs and a Form 14653 non-willful certification.

Missed FBAR UK Precious Metals: Custody Account Guide

Whether a Missed FBAR on UK precious metals is a genuine compliance failure depends almost entirely on how the metal is held. Gold or silver you own directly, including bars in a box only you can open, is generally not a financial account for FBAR purposes. Metal held for you by an institution that accepts it on deposit, pools it, holds a cash balance alongside it, or can deal with it on your instruction can create a reportable foreign financial account, and if the aggregate of your foreign accounts exceeded $10,000 at any point in the year, an FBAR was due.

In the returns we prepare for US citizens and green card holders living in London and elsewhere in the UK, bullion is one of the most misunderstood assets on the balance sheet. Clients tell us gold is not a bank account, so it cannot be on the FBAR. That instinct is right for some structures and wrong for others. This guide works through the actual regulatory text, the IRS's own internal guidance, the Form 8938 rules, the US and UK tax on gains, and the practical routes to catch up if you have fallen behind.

What is an FBAR and why would a bullion holding be caught?

The FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. The underlying regulation, 31 CFR 1010.350, requires each United States person having a financial interest in, or signature or other authority over, a bank, securities or other financial account in a foreign country to report that relationship. The full text is available at https://www.law.cornell.edu/cfr/text/31/1010.350. The IRS confirms at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar that the obligation arises when the aggregate value of your foreign financial accounts exceeded $10,000 at any time during the calendar year, that the report is due April 15 with an automatic extension to October 15, and that it is filed electronically through FinCEN's BSA E-Filing System rather than with your tax return.

Precious metals matter here because the regulation does not stop at bank and brokerage accounts. It defines three categories, and the third, other financial account, is where most metal structures are analysed. It includes:

An account with a person that is in the business of accepting deposits as a financial agency.
An account that is an insurance or annuity policy with a cash value.
An account with a person that acts as a broker or dealer for futures or options transactions in any commodity on or subject to the rules of a commodity exchange or association.
An account with a mutual fund or similar pooled fund which issues shares available to the general public with a regular net asset value determination and regular redemptions.

A bank account is defined as a savings, demand, checking or any other account maintained with a person engaged in the business of banking. A securities account is an account with a person engaged in the business of buying, selling, holding or trading stock or other securities. A UK bank that offers a metal account, or a broker that holds gold exposure inside a securities account, sits squarely inside these definitions.

Is gold in a UK vault reportable on the FBAR? What the IRS actually says

Neither the regulation nor the FBAR form lists precious metals by name. The most specific official statement we have found is in the Internal Revenue Manual chapter used by IRS examiners, IRM 4.26.16, at https://www.irs.gov/irm/part4/irm_04-026-016. It states that precious metals, precious stones or jewels held directly by the person are not financial accounts, and that a safety deposit box is not a financial account. It then adds two qualifications that drive the entire analysis for UK custody arrangements.

A reportable account may exist where the financial institution providing the safety deposit box has access to the contents and can dispose of the contents upon instruction from, or prearrangement with, the person.
A reportable account relationship may exist where a foreign agency holds precious metals on deposit or provides insurance or other services as an agent of the person owning the precious metals.

The IRM also quotes the Bank Secrecy Act definition of financial agency: a person acting for a person as a financial institution, bailee, depository trustee or agent, or acting in a similar way related to money, credit, securities, gold, or a transaction in money, credit, securities or gold. Gold is named expressly, and so is a bailee. That wording is why we do not accept the easy assumption that any physical bar in a professional vault is automatically outside the FBAR.

Two cautions on this authority. First, the IRM is internal guidance for IRS staff, not a regulation, and the language is permissive: a reportable relationship may exist. Second, FinCEN has not, in the sources we reviewed, published guidance that expressly classifies allocated bullion storage one way or the other. The conclusions below are therefore our reading of the regulation and the IRM applied to common UK structures, not a published IRS ruling on any specific product.

Missed FBAR UK precious metals: allocated vs unallocated custody

Allocated metal is bullion that is specifically identified as yours, typically by bar number, weight and assay, and legally remains your property while a custodian stores it. Unallocated metal is a contractual entitlement to a quantity of metal held in a pool, where the provider owes you metal much as a bank owes a depositor money. For practical FBAR analysis, that allocated-versus-unallocated axis is the most useful starting point, although it is not the only factor.

Unallocated and pooled metal accounts. These are the strongest candidates for reporting. The provider holds metal on deposit, owes you a balance, and typically acts on your instructions to buy, sell or convert. That looks like an account with a person in the business of accepting deposits as a financial agency, and it matches the IRM description of a foreign agency holding precious metals on deposit. When a UK bank provides the metal account, it may also be a bank account in its own right. We treat these as reportable unless there is a strong reason otherwise.

Allocated storage with a vaulting provider. This is the genuinely grey area. Your bars are yours and are not lent or pooled, which points towards directly held metal. But most modern allocated services are not passive storage: the provider holds the metal as bailee, insures it, can sell it on your online instruction, and often credits sale proceeds to a cash balance. Those features map closely onto the IRM language about holding metal on deposit, providing insurance or other services as an agent, and being able to dispose of contents upon instruction. The more the arrangement functions as a dealing facility rather than a locked cage, the more likely it is to be treated as a reportable account.

Bullion dealer platforms with a cash wallet. Many platforms let you hold a sterling or dollar balance to fund purchases or receive proceeds. Even if you conclude the metal itself is directly held, a cash balance held by the platform for you is difficult to characterise as anything other than a financial account. In practice this is where many clients who thought they had no reportable account discover they had one.

Metal held inside a brokerage or securities account. Exchange-traded gold products, gold mining shares, or metal positions held through a UK stockbroker sit inside a securities account, which is reportable under the securities account definition regardless of what the underlying exposure is. Note that UK-listed exchange-traded products can also raise separate US passive foreign investment company questions, which are outside the scope of this article.

Commodity futures and options. An account with a broker or dealer for futures or options in any commodity is expressly listed in the regulation as an other financial account. Gold futures traded through a UK broker are reportable on that basis.

Private safe deposit box with no account relationship. Bars or coins in a box to which only you have access, where the provider cannot deal with the contents, fall within the IRM statement that safe deposit boxes and directly held metals are not financial accounts. Metal kept at home is likewise outside the FBAR.

Does Form 8938 apply to physical gold held in the UK?

Form 8938, the FATCA Statement of Specified Foreign Financial Assets, is a separate IRS form filed with your Form 1040, with its own higher thresholds that are higher again for taxpayers living abroad. The IRS answers the precious metals question directly at https://www.irs.gov/businesses/corporations/basic-questions-and-answers-on-form-8938: directly held precious metals, such as gold, are not specified foreign financial assets, and directly held tangible assets such as art, antiques, jewelry, cars and other collectibles are not specified foreign financial assets. The same page confirms that a safe deposit box is not a financial account.

The same IRS page also states that gold certificates issued by a foreign person may be a specified foreign financial asset. That matters for UK holders because an unallocated metal account or a certificate-style entitlement is closer to a financial claim against the issuer than to directly held metal. A financial account maintained by a foreign financial institution is also a specified foreign financial asset. So the same structural analysis that drives the FBAR answer drives the Form 8938 answer, and you should not assume that a metal holding reportable on one form is automatically excluded from the other.

How does the IRS tax gains on UK bullion and gold coins?

The FBAR is an information report and carries no tax. The bigger money question for most clients is the gain on sale. US citizens and residents are taxed on worldwide gains, so a sale of bullion held in London is reportable on Form 8949 and Schedule D exactly as a US sale would be, with proceeds and cost translated into dollars.

The IRS states at https://www.irs.gov/taxtopics/tc409 that net capital gains from selling collectibles, such as coins or art, are taxed at a maximum 28% rate. The definition of collectible comes from Internal Revenue Code section 408(m)(2), reproduced at https://www.law.cornell.edu/uscode/text/26/408, which lists any metal or gem and any stamp or coin. Section 408(m)(3) contains exceptions for certain US-minted coins and trustee-held bullion, but those exceptions exist for retirement account purposes and section 1(h) applies the collectible definition without regard to them for the capital gains rate. In practice, long-term gains on gold and silver bars and on gold coins, including UK coins, are collectibles gains taxed at up to 28% rather than at the lower long-term rates that apply to shares. Metal held for one year or less produces short-term gain taxed at ordinary rates, and investment income surtaxes may also apply depending on your income.

Are Britannia and Sovereign gains tax free in the UK and the US?

On the UK side, HMRC's Capital Gains Manual at https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg78305 states that Sovereigns minted in 1837 and later years and Britannia gold coins are currency but, like all sterling currency, are exempt because of TCGA92/S21(1)(b). The same page confirms that coins which are currency but not sterling, such as Krugerrands, are chargeable assets. Gold and silver bars are also chargeable assets for UK Capital Gains Tax.

This creates the most expensive gap we see in dual-filer bullion portfolios. A UK-resident American who deliberately buys Britannias and Sovereigns to keep gains outside UK Capital Gains Tax has no UK tax on the sale, but the US has no equivalent exemption. The gain is fully taxable on the US return as a collectibles gain, and because no UK tax was paid there is no UK tax available to offset it through the foreign tax credit on Form 1116. The strategy that is efficient for a UK taxpayer can therefore be one of the least efficient for a US taxpayer. By contrast, a gain on bars that is taxed in the UK may generate UK tax that can be credited against the US liability, subject to the foreign tax credit limitation and the relief provisions of the US-UK income tax treaty.

A worked scenario: a London-based American with three metal structures

Illustration only. All figures are hypothetical and assume an exchange rate of 1.30 US dollars to the pound for simplicity; actual FBAR values use the Treasury year-end rate and gains use the rates on the relevant transaction dates.

Daniel is a US citizen who has lived in London for eight years and works in private equity. He files US returns every year but had never filed an FBAR for his metals. During the year he held three arrangements:

Allocated gold bars stored with a UK vaulting service, identified by bar number, insured by the provider, and saleable online with proceeds credited to a sterling cash wallet. Peak wallet balance was the equivalent of 12,000 dollars after a sale.
An unallocated silver account with a UK bank, worth the equivalent of 26,000 dollars at its highest point.
A private safe deposit box containing Britannia coins, which he sold during the year for a gain equivalent to 40,000 dollars, having held them for more than a year.

Our analysis for a file like this runs as follows. The unallocated silver account is reportable on its own and on its own exceeds the 10,000 dollar aggregate threshold, so an FBAR was required regardless of the other two. The cash wallet is a financial account and is listed. The allocated gold is the judgement call; given the insurance, online disposal and cash settlement features, we would generally recommend disclosing it as part of the vaulting relationship rather than relying on an unpublished exclusion, because over-disclosure on an FBAR carries no tax cost. The safe deposit box, with no provider access, is not reported.

On the income side, the Britannia gain is exempt from UK Capital Gains Tax under the sterling currency rule but is a long-term collectibles gain for US purposes, taxed at up to 28%, with no UK tax to credit. If that gain had been left off earlier US returns because Daniel's UK adviser correctly told him it was tax free in the UK, the problem is no longer just a missing information report. It is unreported income, and the right fix changes.

How do you file a late FBAR for a UK precious metals account?

The route depends on whether the only failure was the FBAR itself or whether income was also left off your US returns. The IRS FBAR page linked above says that if you have not been contacted by the IRS about a delinquent FBAR and are not under civil examination or criminal investigation, you should file late FBARs as soon as possible to keep potential penalties to a minimum.

Where all income was reported and only the FBAR was missed, late FBARs are filed through FinCEN's BSA E-Filing System at https://bsaefiling.fincen.treas.gov, selecting the reason for late filing in the form and providing a short, accurate explanation. Note that the IRS withdrew its former Delinquent FBAR Submission Procedures page around July 2026, so this should be treated as filing a late FBAR with an explanation, not as applying to a named IRS programme.

Where gains on metal sales, interest on metal-linked deposits, or other foreign income were not reported, the Streamlined Foreign Offshore Procedures described at https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states are usually the better fit for UK residents. The key requirements are:

Meeting the non-residency test: for US citizens and green card holders, in at least one of the most recent three years for which the return due date has passed, having no US abode and being physically outside the United States for at least 330 full days.
Having failed to report income from a foreign financial asset and pay the tax due.
Certifying on Form 14653 that the failures resulted from non-willful conduct, with a narrative explanation.
Filing delinquent or amended returns for the most recent three years and delinquent FBARs for the most recent six years, with FBARs submitted through BSA E-Filing.
Paying the tax and interest due; eligible filers are not subject to failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties under the procedures.

The non-willful certification needs to be accurate and specific. A credible narrative for a metals holder usually explains the genuine belief that physical gold was not an account, the reliance on UK advice that coin gains were tax free, and the absence of any attempt to conceal the holdings. We draft these carefully because the certification is made under penalties of perjury.

How should precious metals be valued on the FBAR?

The FBAR asks for the maximum value of each account during the year, converted to dollars using the Treasury Reporting Rates of Exchange for the last day of the calendar year. The guidance we reviewed does not expressly say how to value metal held within an account. In the returns we prepare we use a reasonable, documented approach, typically the highest valuation shown on provider statements during the year, or the year-end valuation where intra-year data is unavailable, together with any peak cash balance. Whatever method you use, apply it consistently across years and keep the statements. The IRS page notes that FBAR records generally must be kept for five years from the FBAR due date.

Common mistakes we see with UK metal custody accounts

Treating all bullion as outside the FBAR because it is physical, without examining whether the provider holds it on deposit, pools it, or can dispose of it on instruction.
Overlooking the cash wallet on a dealer platform, which is frequently the account that pushes the aggregate over 10,000 dollars.
Reporting metal on the FBAR but omitting a gold certificate or unallocated entitlement from Form 8938 on the assumption that metal is always excluded.
Leaving UK-exempt Britannia and Sovereign gains off the US return, or reporting them at the lower long-term rates for shares instead of as collectibles gains.
Filing a late FBAR alone when there are also unreported gains, which leaves the income failure unresolved.
Relying on the withdrawn IRS delinquent FBAR page as though it were still a live procedure.

Where this fits in your wider US-UK compliance

Bullion rarely sits alone. The same clients typically hold UK bank and brokerage accounts, pensions and sometimes UK company interests, all of which carry their own US reporting. A missed FBAR on a metals account is often a signal that other foreign accounts were also left off, and the six-year FBAR window under the Streamlined procedures should be built from a complete inventory rather than one asset at a time. Our FBAR filing service and Streamlined Foreign Offshore compliance service handle the account inventory, valuation, late filing and the non-willful narrative together, and our US expat tax return service covers the collectibles gain calculation and foreign tax credit interaction on the underlying return.

The practical summary is simple. Map each metal holding to its legal structure first, report anything that behaves like an account, keep directly held metal and private boxes off the FBAR and Form 8938, tax every coin and bar gain on the US return at collectibles rates whatever the UK treatment, and choose between a late FBAR and the Streamlined procedures based on whether income was missed as well.