Form 8938 for Americans in Panama
Country-specific records and U.S. filing questions for Form 8938 when an American lives, works, owns assets, or has transactions connected to Panama. Identify the records needed before agreeing on preparation scope.
Start with the facts
Country, state, residence, ownership, work location, and tax year facts come before a form conclusion.
Written scope before preparation
Describe your filing needs first. Any paid review, preparation scope, and price are agreed before work begins.
Why specified foreign financial asset reporting requires a Panama records review
Form 8938 reports specified foreign financial assets when the applicable filing-status and residence thresholds are met, with definitions that differ from FBAR. Panama taxes income on a territorial (source-based) basis. Only Panama-source income is taxed. Employment: 0-25%. Corporate: 25%. Capital gains on real estate: 10%. No tax on foreign-source income. Preserve local registration, assessment, payment, withholding, and currency records by tax year rather than copying a local total into a U.S. form. Foreign accounts, securities, interests in entities, contracts, and other specified assets must be inventoried and tested under the tax-year thresholds and exceptions.
Residence, work, and source facts in Panama
A Panamanian cédula (residency card) through the Friendly Nations Visa, Pensionado Visa, or other residency programs strongly supports bona fide residence. Registration with the DGI (tax authority) adds supporting evidence. Build the residence file from the permit, home, family, days, work, and local filing records together. For presence, residence, and work facts in Panama: Panama's proximity to the US makes the 330-day test achievable with careful planning. The country's use of the US dollar simplifies financial tracking. Document all US trips including connecting flights through US airports. Keep payer, contract, service-location, payroll, and entity records separate. Keep the residence timeline, travel calendar, work location, and relevant local returns for the tax year being reviewed.
The Panama accounts, products, and entities to inventory
Examples you may encounter include Banco General, Banistmo (Bancolombia), BAC International Bank. Identify the legal owner, account or product type, currency, and documents available. A local product name alone does not establish its U.S. tax classification.
Documents to request before preparing Form 8938
Gather the following records, along with relevant Panama tax returns, assessments, and payment evidence. Keep original-currency amounts and the exchange-rate method used.
- maximum and year-end account values
- custodian statements and account numbers
- ownership and beneficiary documents
- foreign entity or trust records
- FBAR comparison and exchange-rate support
Country-specific questions that can change the U.S. result
Use these questions to identify missing facts in the Panama file:
- Is the asset held through a bank, broker, pension, trust, or entity?
- Does the country statement show the maximum value?
- Is the asset reportable on Form 8938, FBAR, both, or neither?
Common mistakes for Americans filing from Panama
Check for these form-specific issues:
- treating Form 8938 and FBAR as interchangeable
- omitting non-bank foreign financial assets
- using the filing threshold without considering filing status and residence
Facts to review for Form 8938 in Panama
A U.S. person in Panama needs country-specific FATCA and FBAR account classification to test Form 8938 thresholds and exceptions.
- Panama signed a Model 1 IGA with the US in 2014. Panamanian banks report US person data to the DGI, which shares with the IRS. Panama has moved away from banking secrecy and most banks require FATCA documentation from US citizens.
- Panamanian bank accounts held at Panamanian institutions may be reportable on FBAR when the aggregate maximum value of your reportable foreign financial accounts exceeds $10,000. Despite Panama using the US dollar, accounts at Panamanian banks are still foreign accounts for US reporting. Account definition, ownership, and exceptions still apply.
- Local currency: USD.
Relevant rules: Panama FATCA/FBAR account types and Form 8938 reporting. Sources last verified 2026-09-01 by FileAbroad editorial review.
Frequently asked questions
Does living in Panama automatically require Form 8938?
No. The filing question depends on the form's trigger, the taxpayer's status, the legal owner, the tax year, and the records. Living in Panama identifies the local documents to gather; it does not replace the U.S. instructions or a fact-specific review.
Which Panama records should I gather first?
Start with residence and travel records, local tax identification and returns, bank or investment statements, income and withholding records, the legal documents for any entity or plan, and the original-currency conversion support. Then add the form-specific records listed on this page.
Can a local tax return replace the U.S. Form 8938 analysis?
No. A local return can provide evidence about income, tax paid, residence, or ownership, but U.S. forms use their own definitions and tax-year instructions. Reconcile the local return with the U.S. filing rather than copying its categories.
What happens before FileAbroad prepares Form 8938?
Start with a brief inquiry about the years and filing needs involved. Chip reviews the broad facts and explains the next step. Any paid assessment or preparation scope is agreed separately before work begins.