Pensions reporting for FBARs and f8938

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Pensions reporting for FBARs and f8938


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Old 1st March 2017, 02:00 PM
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Default Pensions reporting for FBARs and f8938

Hi,

I'm really confused about whether to report current and former employer pensions on FBARs and f8938. If they are reportable, I'm also confused what values to report. I spoke to FBAR helpline, and they seemed to suggest employer pensions are usually not reportable. However, they said this depended on the type of pension it might be. I think mine are defined contribution, but I'm not retired or drawing on any of them yet. I've read various internet opinions whether DC needs to be reported and DB not on FBARs. I also read other opinions saying foreign pensions need not be reported on FBARS at all.

However, if they are reportable on either FBAR, f8938, or both, I don't know which values to report. Generally I only receive statements with transfer value figures if I move the pensions to another pension manager. I've actually been reporting transfer values on the FBARS, but I now believe transfer values were the wrong values to report? Should I just report 0 because I'm not sure? Can someone please help me with these questions??

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Old 1st March 2017, 02:04 PM
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Just to be clear, I am referring to foreign employer pensions!

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Old 1st March 2017, 03:04 PM
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As I understand it, Defined Benefits pensions (the "old fashioned" type of employer pensions) are not reportable. Period.

Defined contribution pensions aren't normally reportable unless you have some level of control over your funds - i.e. you can direct how they are invested (even if only within the various funds allowed by the employer pension) - or unless you are entitled to withdraw your money early (usually with a penalty of some variety). If in doubt, sure, report them on the FBAR, but there is always that little box you can tick that says that the balance is unknown. If there is a problem with that approach, they'll get back to you - but at least you've reported the account.
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Bev

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Old 1st March 2017, 10:25 PM
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Thank you, Bev! What if it is for form 8938? Should I just tick the 0-$50K box?

I think I may have been reporting the wrong values on both 8938 and FBARS for the past several years, i.e. using the transfer values instead of the market values. Do you think I need to submit amended forms for all those years, or can I just submit correct values (or what I believe are correct) going forward and hope for the best? Or just tick 0 since I'm not sure which values are correct?

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Old 2nd March 2017, 12:13 AM
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I would not worry about amending past forms and report what you believe is the correct value going forward.

If you get a periodic statement with balance I would just report that and not worry beyond that.

If you do not get at least a quarterly statement I think it is reasonable to say that you do not know the max value and thus report 0-50k. Or alternatively if you know the amount will likely be in one of the other ranges, check that box, but don't enter a max value for the 8938 and check the Max balance unknown on the FBAR.
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Old 2nd March 2017, 07:46 AM
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Thanks to you both!!

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