Form 8938, Statement of Specified Foreign Financial Assets Does Not Apply to Solo 401k Plans or IRAs


I’m looking for a clarification on reporting of foreign assets held under my solo 401k plan. I looked thru the article you all posted which clarifies that the FBAR does not need to be filed for such assets.
However, does the form 8938 also  not need to be filed? it seems like this is the case but thought it best to check with you.


No it does not apply to 401k plans including solo 401k plans and IRAs per the section titled  “Assets Not Required to be Reported” of the Form 8938 instructions.

Certain Financial Accounts

The following financial accounts and the assets held in such accounts are not specified foreign financial assets and do not have to be reported on Form 8938.

  1. A financial account that is maintained by a U.S. payer, such as a domestic financial institution. In general, a U.S. payer also includes a domestic branch of a foreign bank or foreign insurance company and a foreign branch or foreign subsidiary of a U.S. financial institution. Examples of financial accounts maintained by U.S. financial institutions include:
    • U.S. mutual funds accounts,
    • IRAs (traditional or Roth),
    • Section 401(k) retirement accounts,
    • Qualified U.S. retirement plans, and
    • Brokerage accounts maintained by U.S. financial institutions.

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About Mark Nolan

Each day I speak with energetic entrepreneurs looking to take the plunge into a new venture and small business owners eager to take control of their retirement savings. I am passionate about helping others find their financial independence. Having worked for over 20 years with some of the top retirement account custodian and insurance companies I have a deep and extensive knowledge of the complexities of self-directed 401ks and IRAs as well as retirement plan regulations. Learn more about Mark Nolan and My Solo 401k Financial >>

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