AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
For a married couple filing jointly and living in the US, Form 8938 is required if specified foreign financial assets are worth more than $100,000 on the last day of the year or more than $150,000 at any time in it. Married filing separately in the US, each spouse uses $50,000 and $75,000. Couples living abroad use $400,000 and $600,000 jointly, or $200,000 and $300,000 each if filing separately.
The thresholds
The IRS sets out the Form 8938 thresholds on its "Do I need to file Form 8938?" page (reviewed September 2026) and in its comparison with the FBAR (September 2026).
| Filing status and residence | Last day of the year more than | Or at any time in the year more than |
|---|---|---|
| Married filing jointly, living in the US | $100,000 | $150,000 |
| Married filing separately, living in the US | $50,000 | $75,000 |
| Married filing jointly, living abroad | $400,000 | $600,000 |
| Married filing separately, living abroad | $200,000 | $300,000 |
| Single, living in the US (for comparison) | $50,000 | $75,000 |
Either test is enough: if your assets pass the year-end figure or the any-time figure, you file. Form 8938 is attached to your income tax return and due with it, including extensions. If you do not have to file a return for the year, the IRS Q&A says you do not file Form 8938 either.
Which Nigerian assets count
The IRS basic Q&A on Form 8938 (reviewed August 2026) explains what is a specified foreign financial asset.
- Count: deposit and brokerage accounts at foreign financial institutions, such as a Nigerian savings, current, domiciliary or fixed deposit account, or a Lagos stockbroking account.
- Count if held outside an account: shares or securities of a non-US company, notes or bonds of a foreign issuer, and interests in foreign entities held for investment.
- Count: an interest in a foreign pension plan, reported in Part VI of the form according to the instructions. Whether a Nigerian RSA is treated this way has not been confirmed on an IRS page; ask a preparer.
- Do not count: foreign real estate you hold personally, such as a house in Abuja or land in Ogun State, and foreign currency you hold directly.
Assets are valued at their maximum value during the year and converted at the Treasury Bureau of the Fiscal Service rate for the last day of the tax year, according to the Form 8938 instructions.
Joint and separate filers: worked examples
Example only. Rate illustrative: ₦1,500 = $1. Uche and Ada live in Maryland and file jointly. They hold:
| Asset | Max value in year | In dollars | Year-end value |
|---|---|---|---|
| Joint fixed deposit, Lagos | ₦90,000,000 | $60,000 | $58,000 |
| Uche's domiciliary account | $35,000 | $35,000 | $20,000 |
| Ada's shares in a Nigerian-listed company (held directly) | ₦45,000,000 | $30,000 | $27,000 |
| House in Enugu | — | Not reported | — |
Total maximum value: $60,000 + $35,000 + $30,000 = $125,000; total year-end value: $58,000 + $20,000 + $27,000 = $105,000. The year-end total is more than $100,000, so they file Form 8938 with their joint return, even though the any-time total is under $150,000. The house does not count.
If they filed separately, each would test against $50,000 at year end and $75,000 at any time, using their own assets and their share of the joint deposit. How a jointly owned asset is counted between separate filers is set out in the Form 8938 instructions; ask a preparer before splitting values.
Filling in the form
The Form 8938 instructions (Rev. November 2021, still in use) set out a few points that matter for Nigerian assets:
- Assets already reported on certain other forms, such as Form 3520, 5471, 8621 or 8865, are not listed again in detail, but you identify the other form in Part IV and still count the value towards your threshold.
- For a foreign pension, report the value of your interest at year end; if you have had no distributions and have no readily available information about its value, the instructions allow zero.
- Income from the assets, such as Nigerian interest or dividends, still has to be reported on your return in the usual way; Form 8938 only discloses the assets.
Penalties and the FBAR
- The IRS comparison page gives a penalty of up to $10,000 for failing to file, plus up to $10,000 for each 30 days after an IRS notice, to a maximum of $60,000.
- Form 8938 does not replace the FBAR. The FBAR threshold is $10,000 in aggregate, so most couples who file Form 8938 also file an FBAR, separately through FinCEN.
- For the full comparison, see Form 8938 and FBAR for Nigerian accounts.
Living in the US or abroad?
The higher thresholds for people living abroad apply only if you meet the IRS test for living abroad, which the Form 8938 pages explain. A couple who moved back to Lagos part-way through the year should check that test before using the higher figures. If only one spouse lives abroad, read the instructions carefully, because the joint and separate rules can apply differently. This is general information, not tax advice.
Where Pryme fits
Working out maximum values means having full-year records. Pryme customers can download a statement for each currency they hold, and keep NGN, USD, GBP and EUR in one account. Naira deposits are held by a licensed Nigerian microfinance bank; ask your preparer how they fit in your Form 8938 and FBAR. If you also save in naira, see Savings Boxes.
Questions people ask
What is the Form 8938 threshold for married filing jointly?
Living in the US, more than $100,000 on the last day of the year or more than $150,000 at any time. Living abroad, $400,000 and $600,000.
Is a house in Nigeria reported on Form 8938?
No. The IRS says foreign real estate held personally is not a specified foreign financial asset. A company that owns the property may be.
Do married couples filing separately each use $50,000?
Yes, if living in the US: each spouse uses more than $50,000 at year end or $75,000 at any time.
If I file Form 8938, do I still need an FBAR?
Yes. Form 8938 does not replace the FBAR, which has a $10,000 aggregate threshold and is filed separately with FinCEN.
Sources
- IRS: Do I need to file Form 8938? (reviewed 20 Sep 2026) · accessed Oct 2026
- IRS: Comparison of Form 8938 and FBAR requirements (reviewed 19 Sep 2026) · accessed Oct 2026
- IRS: Basic questions and answers on Form 8938 (reviewed 17 Aug 2026) · accessed Oct 2026
- IRS: Instructions for Form 8938 (Rev. November 2021) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.