EPF and PPF for US Persons: FBAR, Deemed Trust and Form 3520

Guide · Last reviewed October 10, 2026 · Legal and tax review: pending

Indian provident funds are retirement savings, but for a US person they raise several reporting questions at once. The FBAR question is the most common. The deemed trust question is less understood and can bring in Form 3520 and 3520-A. Each needs its own analysis.

1. FBAR: generally reportable

Practitioners generally treat the Employees' Provident Fund (EPF) as reportable on the FBAR, even though it is a pension-type savings arrangement. The US-India FATCA agreement reporting by Indian institutions does not remove the individual's own FBAR obligation. PPF accounts are also commonly reported on the FBAR, but the right treatment should be confirmed for your account.

2. The deemed trust question

EPF is held in a trust under Indian law. The US question is whether that trust is a foreign trust for US tax purposes, and if so, whether any US person involved must report it. A US person who is a beneficiary or who receives distributions can face reporting obligations on Form 3520, and the trust may need an information return on Form 3520-A.

The IRS instructions for Form 3520 describe specific exemptions for certain tax-favored foreign retirement and savings trusts, including an exemption in Revenue Procedure 2020-17 for certain eligible individuals. Whether an EPF or PPF account fits any exemption is a fact-specific determination. Do not assume an exemption applies because the account is a retirement account.

Key ideaTwo different questions: (1) Is the account reportable on the FBAR? (2) Does the account create trust reporting on Form 3520 or 3520-A? Often both are yes, sometimes only the first is yes, and sometimes neither applies. The answer depends on the account and on your history.

3. Form 8938 and other items

Some foreign retirement plans are excluded from Form 8938 when they meet specific conditions. Whether EPF or PPF meets those conditions must be checked. Earnings credited to these accounts each year also raise US income tax questions, including whether they are taxed as they accrue or when withdrawn. That answer affects the amounts reported.

4. Withdrawals and transfers

Withdrawal or transfer of EPF or PPF funds can trigger reporting and tax consequences in both countries.
Foreign tax credit rules may apply to Indian tax paid on withdrawals.
Timing of withdrawals relative to a change in residency or citizenship should be planned in advance.

5. Past years

If EPF or PPF was not reported in prior years, there may be correction options, including amended filings and delinquent FBAR procedures. Eligibility depends on the facts, including whether the failure was willful. Do not file a correction without an analysis of the options and their consequences.

WarningTrust reporting penalties can be significant, and they can apply even when no tax is owed. Treat any EPF or PPF question as a reason for a professional review, not a routine filing.

What to gather for a review

EPF and PPF passbooks or statements for each year, including contributions, interest and withdrawals.
Your employment history and the employer's status (for EPF).
Your residency and citizenship dates.
Any past FBAR, Form 8938 or Form 3520 filings, or notices received.

General educational information. EPF, PPF and trust reporting depend on individual facts and on the current text of the IRS instructions and regulations. Confirm all points against irs.gov and fincen.gov, and consult a qualified professional before filing.