Additional Reporting Requirements for US Digital Nomads and Expats Doing Business Abroad

If you are a US digital nomad, or other expat doing business abroad, you likely have thought about the tax consequences of where you are living. We have covered some of these topics in a prior blog. One thing to also be aware of is that there are additional, non-tax reporting requirements. The basic list is pretty short, but the requirements are important. These requirements revolve around:

• holding money in a non-US bank account

• having ownership of a foreign business

Reporting on Holding Funds in a Bank Account Outside the US

Any US citizen that holds the equivalent of at least $10,000 in total in foreign bank accounts at any time during the year, needs to file a report of this. Note the two important criteria here. Firstly, the amounts are aggregate. So, it is not possible to get away from this by simply splitting funds between several accounts. Second, the threshold is at any time during the year; not only at year-end. This can easily be reported on a form TDF 90-22.1. Alternatively, you can file this online on the US FinCEN website at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar.

Also, as a separate filing requirement, any citizen that holds funds over the following amounts needs to file a ‘form 8938’ with the IRS. These amounts are for US citizens living abroad (amounts as of December 2025; subject to change):

• Unmarried, living abroad: $200,000 at year end, or $300,000 any time during the year

• Married, living abroad: $400,000 total at year end, or $600,000 total any time during the year

(https://www.irs.gov/instructions/i8938#en_US_2020_publink100049974)

This form can be filed with your yearly tax return.

Currency exchange rate fluctuations and language barriers sometimes make this reporting more difficult than it might seem. However, an honest effort to comply, should (hopefully) go a long way.

Reporting on Ownership of a Foreign Business

US citizens doing business abroad may have to disclose their business activity to the US government, even if no tax would be due. It is important to point out that ‘ownership’ means any percentage of ownership; not just total. These reporting requirements are tangentially related to tax filings. They are not tax filings themselves though. So, you would likely miss filing these forms if you use a tax software to prepare your taxes. These forms cover everything from having a foreign business partner to complex tax avoidance schemes.

There are numerous possible forms for the ‘foreign business ownership’ reporting; depending on how the business is structured. Because of this, we suggest working with a US CPA in order to make sure the ‘foreign business ownership’ reporting is correct.

Summary

Many US expats are not aware of the additional reporting requirements necessary about their finances. We have outlined the two major ones above. Of course, it is typically necessary to file a US tax return as well. Please see our prior blog for an overview regarding that.

This is one of several blogs about business and tax issues faced by digital nomads and other expats. To get notifications of future blogs, please follow us on LinkedIn.

The advice given here is only general in nature. We suggest contacting a CPA to discuss your specific situation.

No part of this article was written by artificial intelligence (AI). AI is only capable of summarizing. It does not know if the sources it is drawing from are correct, and it does not understand how law and accounting rules operate. Please do not rely on AI to answer legal or financial reporting questions.

Information valid as of the date of posting; December 30, 2025.