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The short answer
Form 8938 reports assets, not income: the T-bill interest itself goes on your return as interest. What Form 8938 asks about is the account that holds the T-bills. If you hold Nigerian T-bills through a Nigerian bank or stockbroker account, you report that account, at its maximum value in the year, once your specified foreign financial assets exceed the threshold, which for a single filer living in the US is $50,000 on the last day of the year or $75,000 at any time.
Nigerian Treasury bills are popular with US-based Nigerians because yields in naira are high and the issuer is the Federal Government. Buying them means holding naira in Nigeria, usually through a bank or stockbroker, and that brings two US questions: how the interest is taxed, and whether the holding has to be disclosed. Form 8938 answers the second.
What Form 8938 actually reports
Form 8938, the Statement of Specified Foreign Financial Assets, is attached to your income tax return. The IRS's basic questions and answers (reviewed 17 August 2026) say specified foreign financial assets include financial accounts maintained by a foreign financial institution, such as deposit and brokerage accounts at a foreign bank or broker, and certain assets held for investment outside an account, including notes and bonds issued by a foreign person. Crucially, you "do not need to separately report the assets of a financial account": the account is the reportable item.
The income from the T-bills is reported elsewhere on your return; see how Nigerian T-bill interest is taxed in the US.
How your T-bills are held decides what you report
| Holding route | What counts for Form 8938 |
|---|---|
| Through a Nigerian bank (bank buys on your behalf) | Your account at the bank, including the T-bills it holds for you |
| Through a Nigerian stockbroker or investment platform | Your brokerage account, including the T-bills |
| Through a Nigerian money market or T-bill fund | Your interest in the fund (and possible PFIC reporting) |
| Through a US brokerage account | Not reported: the IRS excludes US-based brokerage accounts |
The Q&A does not specifically address foreign government securities held directly outside any account. If you bought through a bank or broker, your bills are usually recorded in an account there, which puts them in the first two rows. Ask your bank or broker how your holding is recorded, and confirm treatment with a preparer if anything is unusual. Buying routes are explained in buying Nigerian T-bills from the US through a stockbroker.
Thresholds
The IRS's comparison of Form 8938 and FBAR (reviewed 19 September 2026) gives these thresholds, added across all your specified foreign financial assets:
| Filer | Last day of year more than | Or at any time more than |
|---|---|---|
| Single or married filing separately, living in the US | $50,000 | $75,000 |
| Married filing jointly, living in the US | $100,000 | $150,000 |
| Single or married filing separately, living abroad | $200,000 | $300,000 |
| Married filing jointly, living abroad | $400,000 | $600,000 |
If you are not required to file an income tax return, you are not required to file Form 8938. Once you cross the threshold, all specified assets are listed, including small ones.
Valuing naira holdings
The Q&A says to report the maximum value during the year, and that periodic account statements may be used unless you have reason to know they do not reasonably reflect the maximum. The IRS comparison page says values are converted to dollars at the end-of-year exchange rate. For T-bills, the account's highest value often falls just before a bill matures or just after a rollover lands.
Worked example
Example only, with an illustrative rate of ₦1,500 to $1 at year end. You are single and live in Texas. Your Nigerian brokerage account peaked at ₦90,000,000 in T-bills and cash in August, and held ₦60,000,000 on 31 December. Your Nigerian savings account peaked at ₦9,000,000. Converted at ₦1,500, the maximum values are $60,000 and $6,000, total $66,000. At year end the accounts held ₦60,000,000 ($40,000) plus, say, ₦6,000,000 ($4,000): $44,000, below $50,000. The any-time test uses each asset's maximum value, $66,000, below $75,000, so on these figures you would not file Form 8938. FBAR is different: the accounts together exceeded $10,000, so an FBAR is due. Do the conversion with the actual year-end rate your preparer uses.
Form 8938 and FBAR are separate
The Q&A says Form 8938 does not replace FinCEN Form 114. The FBAR threshold is lower: more than $10,000 in aggregate across foreign accounts at any time in the calendar year, filed through FinCEN's BSA E-Filing system, due 15 April with an automatic extension to 15 October. The IRS comparison page lists Form 8938 penalties of up to $10,000 for failure to file, plus up to $10,000 for each 30 days after an IRS notice, to a maximum of $60,000. For both forms side by side, see Form 8938 and FBAR for Nigerian accounts.
Where Pryme fits
Pryme does not sell T-bills. A Pryme Personal Account holds naira with a licensed Nigerian microfinance bank, regulated by the CBN and insured by the NDIC up to the applicable limit, alongside dollars; ask your preparer whether your balances with Pryme belong in your FBAR and Form 8938 totals. Statements in the app, including verifiable statements through VerifyDoc.ai, help you find each account's maximum value.
Questions people ask
Do I report Nigerian Treasury bills on Form 8938?
You report the Nigerian bank or brokerage account that holds them, not each bill, once your foreign assets exceed the threshold. The IRS says assets inside a foreign account are not separately reported.
What is the Form 8938 threshold for a single person in the US?
More than $50,000 on the last day of the tax year or more than $75,000 at any time, per the IRS comparison page reviewed 19 September 2026.
Is T-bill interest reported on Form 8938?
No. Form 8938 lists assets. The interest is reported as income on your return, in the usual places for interest.
Do I still need an FBAR if I am below the Form 8938 threshold?
Possibly. The FBAR threshold is more than $10,000 in aggregate across foreign accounts at any time in the year, which is far lower.
Sources
- IRS: Basic questions and answers on Form 8938 (reviewed 17 Aug 2026) · accessed Oct 2026
- IRS: Comparison of Form 8938 and FBAR requirements (reviewed 19 Sep 2026) · accessed Oct 2026
- IRS: Do I need to file Form 8938? (reviewed 20 Sep 2026) · 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.