What foreign financial assets do I need to report on Form 8938 under FATCA?

Yes, Form 8938 (Statement of Specified Foreign Financial Assets) is a completely separate requirement from the FBAR (FinCEN Form 114). They are administered by different agencies (IRS vs. FinCEN), have different filing thresholds, cover somewhat different assets, and have different due dates. Filing one does not satisfy the other. Many U.S. persons with foreign assets must file both. Form 8938 was created under the Foreign Account Tax Compliance Act (FATCA) and is attached to your annual income tax return.

The filing thresholds for Form 8938 depend on whether you live in the U.S. or abroad and your filing status. For taxpayers living outside the U.S. (which applies to you in Singapore), the thresholds are higher: Single filers must file if the total value of specified foreign financial assets exceeds $200,000 at the end of the year or $300,000 at any time during the year. Married filing jointly, the thresholds are $400,000 at year-end or $600,000 at any time. For comparison, domestic filers have lower thresholds of $50,000/$75,000 (single) or $100,000/$150,000 (married filing jointly). With $430,000 in assets, you exceed the year-end threshold for single filers abroad.

Specified foreign financial assets include: financial accounts maintained at foreign financial institutions (your bank and brokerage accounts in Singapore), stock or securities issued by a non-U.S. person (your Singapore private company stock), any financial instrument or contract held for investment that has a non-U.S. issuer or counterparty, and any interest in a foreign entity. Your Singapore private company stock qualifies even though it is not held in a financial account — direct ownership of foreign securities is reportable. If the company is not publicly traded, you report it based on your best estimate of fair market value.

For the private company stock, you must report the fair market value. The IRS instructions state that if no public market price is available, you should use a reasonable estimate. This could be based on the company's book value, a recent valuation performed for other purposes (such as a funding round), or your pro-rata share of the company's net asset value. You should document your valuation methodology and keep records supporting your estimate. Reporting a zero or nominal value when the actual value is materially higher could be treated as a failure to report.

The penalty for failure to file Form 8938 is $10,000, with an additional $10,000 for each 30-day period of continued failure after IRS notice, up to $50,000. Beyond these specific penalties, failure to file Form 8938 can result in a 40% penalty on any underpayment of tax attributable to undisclosed foreign financial assets. The statute of limitations on your entire tax return extends to six years if you omit from gross income an amount attributable to a specified foreign financial asset that exceeds $5,000 and is not properly reported.