Indian Accounts Reporting Chart
Use this chart to start a review, not to finish one. "Usually" means the most common treatment for a US person in a typical situation. "Review" means the answer depends on facts that need professional analysis.
| Indian account or product | FBAR | Form 8938 | Other forms and issues |
|---|---|---|---|
| Savings account (regular, NRE, NRO) | Usually yes, counted toward the aggregate | Usually yes, if thresholds are met | Interest is US taxable income. NRO accounts may carry extra Indian tax rules; review. |
| Fixed deposits | Usually yes | Usually yes | Interest reporting and currency conversion are needed each year. |
| Demat and brokerage accounts (Indian stocks) | Usually yes | Usually yes | Direct stock gains are generally taxed as capital gains. Foreign stock may raise PFIC questions; review. |
| Mutual funds (Indian AMC funds) | Usually yes | Usually yes | Usually PFICs: Form 8621 may be required, with complex tax calculations. See mutual funds and PFIC. |
| Life insurance with cash surrender value (LIC, endowment, whole life) | Usually yes, review the policy | Review | Insurance exceptions to PFIC may apply to some policies; review. See life insurance. |
| ULIP (unit-linked insurance plan) | Review | Review | Investment-linked returns raise PFIC questions. Review each policy. |
| Employees' Provident Fund (EPF) | Generally yes | Review | Deemed trust and Form 3520 / 3520-A questions. See EPF and PPF. |
| Public Provident Fund (PPF) | Review; often reported | Review | Trust characterization and retirement-plan exceptions must be checked. See EPF and PPF. |
| National Pension System (NPS) | Review | Review | Treatment depends on account structure and US tax analysis of earnings. |
| Real estate held directly in India | Generally no | Generally no | Rental income and capital gains are still US-taxable; treaty and foreign tax credit issues apply. |
| Gold or other physical assets at home | Generally no | Generally no | Not financial accounts, but related income and sales may be taxable. |
How to use the chart
- Find each account or product you have held in each year.
- Mark the forms that usually apply, then the rows marked "Review."
- Gather the year-end and peak balances for each account.
- Convert balances to US dollars using the method FinCEN requires, not an estimate.
- Discuss the review rows with a professional before filing.
Why this chart mattersSeveral forms can apply to one account. A single demat account of mutual funds can trigger the FBAR, Form 8938 and Form 8621. Filing only one of them can leave the others open.
Forms that often come up together
| Form | Filed with | Purpose |
|---|---|---|
| FinCEN Form 114 (FBAR) | Separately, electronically to FinCEN | Reports foreign accounts above the aggregate threshold |
| Form 8938 | Income tax return | Reports specified foreign financial assets under FATCA |
| Form 8621 | Income tax return | Reports PFIC holdings, such as many Indian mutual funds |
| Form 3520 | Income tax return, separate due date | Reports certain foreign trust transactions and distributions |
| Form 3520-A | Separate return | Annual information return for certain foreign trusts |
This chart is a general reference and may not reflect future rule changes, specific exceptions or treaty positions. Confirm each row with official sources and a qualified professional before relying on it.