Turns out most assets held offshore are considered foreign assets...
The IRS has identified “specified foreign financial assets” which you're required to report even if no income or distributions have been received with respect to that asset.
Specified foreign financial assets include:
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Savings,
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deposit,
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checking and brokerage accounts held with a foreign financial institution,
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Stock or securities issued by a foreign corporation,
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A note, bond or debenture issued by a foreign person,
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A swap or similar agreement with a foreign counter-party,
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An option or other derivative instrument that is entered into with a foreign counter-party or issuer,
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A partnership interest in a foreign partnership,
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An interest in a foreign retirement plan, pension, or deferred compensation plan,
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An interest in a foreign estate,
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Any interest in a foreign-issued insurance contract or annuity with a cash-surrender value,
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Any financial account maintained by a foreign financial institution,
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Reportable assets held by a disregarded entity.
Savings,
deposit,
checking and brokerage accounts held with a foreign financial institution,
Stock or securities issued by a foreign corporation,
A note, bond or debenture issued by a foreign person,
A swap or similar agreement with a foreign counter-party,
An option or other derivative instrument that is entered into with a foreign counter-party or issuer,
A partnership interest in a foreign partnership,
An interest in a foreign retirement plan, pension, or deferred compensation plan,
An interest in a foreign estate,
Any interest in a foreign-issued insurance contract or annuity with a cash-surrender value,
Any financial account maintained by a foreign financial institution,
Reportable assets held by a disregarded entity.
The IRS has indicated that certain assets are NOT considered specified foreign financial assets and therefore do not have to be reported. These include:
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Foreign real estate (e.g., personal residence or rental property), unless the real estate is held through a foreign entity, such as a corporation, partnership, trust or estate. In such cases, the interest in the entity is reported on Form 8938,
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Foreign currency,
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Directly held shares of a U.S. mutual fund that owns foreign stocks and securities,
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Financial account maintained by a U.S. financial institution that holds foreign stock and securities (e.g., U.S. mutual fund accounts; IRAs (traditional or Roth),
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401(k) retirement plans, qualified U.S. retirement plans; and brokerage accounts maintained by U.S. financial institutions.
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A financial account maintained by a U.S. branch or U.S. affiliate of a foreign financial institution.
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Financial accounts, such as a depository, custodial or retirement account, held through a foreign branch or foreign affiliate of a U.S.-based financial institution.
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Payments or the rights to receive the foreign equivalent of Social Security.
Foreign real estate (e.g., personal residence or rental property), unless the real estate is held through a foreign entity, such as a corporation, partnership, trust or estate. In such cases, the interest in the entity is reported on Form 8938,
Foreign currency,
Directly held shares of a U.S. mutual fund that owns foreign stocks and securities,
Financial account maintained by a U.S. financial institution that holds foreign stock and securities (e.g., U.S. mutual fund accounts; IRAs (traditional or Roth),
401(k) retirement plans, qualified U.S. retirement plans; and brokerage accounts maintained by U.S. financial institutions.
A financial account maintained by a U.S. branch or U.S. affiliate of a foreign financial institution.
Financial accounts, such as a depository, custodial or retirement account, held through a foreign branch or foreign affiliate of a U.S.-based financial institution.
Payments or the rights to receive the foreign equivalent of Social Security.
Please note the lists above are not all inclusive. The penalty for failure to file this form or late filing is $10,000. If you receive a notice from the IRS for failure to file this form and do not file it within 90 days of the IRS notice, additional penalties may be imposed.