Foreign life insurance reporting

Yes — a foreign-issued life insurance or annuity contract with a cash value counts as a foreign financial account for FBAR purposes, reportable once your combined foreign accounts cross $10,000, regardless of what the policy is called locally or how the issuing country taxes it. A classic example is French assurance vie: the French tax deferral that makes these policies attractive locally does nothing to exempt them from US reporting. Beyond FBAR, the investment component inside a cash-value policy can also trigger separate PFIC reporting on Form 8621 if it holds pooled or fund-like investments — see the full US reporting rules for foreign life insurance for how these obligations stack.

There's no special threshold just for insurance policies — a foreign life insurance or annuity contract with cash value is measured against the same $10,000 aggregate FBAR threshold as every other foreign account you hold, combined. A policy with a $6,000 cash value alongside a $5,000 foreign bank account crosses the threshold and makes both accounts reportable, even though neither one individually reaches $10,000. See the full FBAR filing guide for how the aggregate calculation works across different account types.

Use the cash surrender value — what you'd actually receive if you fully redeemed the policy today, meaning its accumulated value minus any surrender fees or charges — not the policy's face value or death benefit, which is a common and costly mixup. Your insurer's year-end statement typically states this figure in local currency; convert it to US dollars using the appropriate exchange rate for FBAR purposes, the same way you would any other foreign account balance. See the full assurance vie reporting guide for a worked example of pulling the correct surrender value off a real policy statement.

Yes, fundamentally — term life insurance has no cash value or investment component, so there's nothing to report on an FBAR at all, while whole, universal, or endowment life insurance builds a savings component that functions as a financial account and is reportable once the aggregate threshold is met. That savings component is also what creates PFIC exposure: the policy structure itself, not the "life insurance" label, determines whether the underlying investment is treated as a passive foreign investment company requiring its own Form 8621. See the full PFIC rules explained for how insurance wrappers get evaluated against these criteria.

Potentially, yes — a foreign cash-value life insurance policy can qualify as a "specified foreign financial asset" for Form 8938 purposes, but FATCA's thresholds are much higher than the FBAR's $10,000: $200,000/$300,000 for a single expat filer, $400,000/$600,000 married filing jointly, so plenty of policies clear the FBAR bar without coming close to the FATCA one. A single policy can realistically create three separate, independent filing obligations — FBAR, Form 8938, and potentially Form 8621 for the PFIC-classified investments inside it — and clearing one threshold says nothing about the others. See the full comparison of Form 8938 versus other foreign asset disclosure forms and the PFIC rules for how each threshold and obligation is assessed separately.

Yes — FBAR treats a foreign-issued annuity contract with a cash value the same way it treats cash-value life insurance: as a foreign financial account, reportable once your combined foreign accounts cross $10,000. This applies whether the annuity is structured as a standalone retirement product or bundled with life insurance features, since what matters for FBAR is the presence of an accessible cash value, not the specific product category. See the foreign life insurance and annuity reporting guide for how these cash-value contracts are valued and reported.