Do I have to report my foreign life insurance on the FBAR?
Foreign life insurance policies with a cash surrender value are reportable on both the FBAR and Form 8938 once the applicable thresholds are met. Term-life policies without a cash accumulation feature generally are not reportable because they lack a balance to value.
Policies that are reportable:
- Whole life policies with cash surrender value
- Universal life policies
- Endowment policies
- Investment-linked insurance (unit-linked, PPLI, ILAS)
- Annuities with foreign insurers
Policies that are generally not reportable:
- Term life with no cash value
- Group term employer-provided without cash value
- Pure protection products with no accumulation
Valuation on the forms:
| Form | Value to use |
| FBAR | Maximum cash surrender value during the year |
| Form 8938 | Maximum cash surrender value during the year |
| Foreign currency | Convert to USD using the Treasury year-end rate |
Other U.S. tax considerations:
- Section 7702 / 7702A: U.S. life insurance rules often not met by foreign policies, causing MEC-like treatment
- Section 4371 excise tax: 1% on premiums paid to foreign insurers (reported on Form 720)
- PFIC risk if the policy is a wrapper around foreign mutual funds
Last updated on April 29, 2026
