Expat Tax Document Checklist: Foreign Income and Accounts

An expat tax document checklist asks a US client living abroad for five sets of records: foreign pay records and the foreign tax return, each foreign account's highest balance, a travel log of days in and out of the US, housing costs, and proof of foreign tax paid. Each amount carries its currency and exchange rate.

Foreign income documents on the expat tax document checklist

Foreign income documents on the expat tax document checklist are the records a foreign employer or tax office produces in place of a W-2: payslips, the employer's annual pay statement and the client's foreign tax return. They show what was earned, where the work was done and what foreign tax was withheld, which are the facts the US forms need.

A foreign employer does not issue a W-2, so the firm has to assemble the same facts from local paper. Ask for:

• Monthly or periodic payslips for the whole year, so the preparer can see gross pay, bonuses, allowances and withholding month by month.
• The employer's annual pay statement, the local equivalent of a year-end summary. Its name differs by country.
• The foreign tax return as filed, with any assessment notice the foreign tax office issued.
• Any housing, school or relocation allowance letters, since those often appear on payslips under local labels.
• Records of self-employment income abroad, if the client also freelances: invoices and the local business tax filing.

Where the work happened matters. IRS Publication 54 (Tax Guide for U.S. Citizens and Resident Aliens Abroad, revised December 2025, for tax year 2025) says "the source of salary, wages, commissions, and other personal service income is the place where you perform the services." A payslip that shows the work location, or a contract that names it, answers that question on paper.

These records feed two US forms most often. Form 2555 covers the foreign earned income exclusion, and the Instructions for Form 2555 (2025) say that for 2025 the maximum exclusion is $130,000. Form 1116 covers the foreign tax credit. Publication 54 says a client who elects the exclusion cannot take a credit or deduction for foreign taxes on the income excluded. Which route applies is the preparer's decision; the checklist collects the papers both need.

The rest of an expat's file looks like any other client's. The tax document checklist for W-2 employees covers the US-side basics, such as a US brokerage 1099 or a 1098 on a US home.

Which foreign account records do expat clients owe you?

Expat clients owe the firm a list of every foreign financial account, the highest balance each one reached during the year, and the year-end statement for each. Those three items support both the FBAR (FinCEN Form 114) and Form 8938, which have different thresholds, different filing places and different value rules.

The IRS page on the Report of Foreign Bank and Financial Accounts (FBAR) (last reviewed 30 July 2026) says a US person must file when they have a financial interest in, or signature authority over, foreign accounts whose aggregate value "exceeded $10,000 at any time during the calendar year reported." The FBAR is filed electronically through FinCEN's BSA E-Filing System, not with the tax return. It is due April 15 of the year after the year reported, so the FBAR for 2026 accounts is due April 15, 2027, with an automatic extension to October 15, 2027.

The same page lists the records to keep for each account: the account name and number, the bank's name and address, the account type and the maximum value during the year. It says to keep them for five years from the FBAR due date. Those fields make a good column set for the account list.

Form 8938 is filed with the income tax return. The Instructions for Form 8938 (revised November 2021) set these thresholds for taxpayers living outside the United States:

• Unmarried, or married filing separately: more than $200,000 on the last day of the tax year or more than $300,000 at any time during the year.
• Married filing jointly: more than $400,000 on the last day of the tax year or more than $600,000 at any time during the year.

The instructions say an account's maximum value may be taken from periodic account statements, unless the filer knows or has reason to know the statements do not reasonably estimate it. That is why the checklist asks for every statement, not just December. The IRS comparison of Form 8938 and FBAR requirements (last reviewed 19 September 2026) lays the two side by side.

Ask the client to list accounts that are easy to forget: a pension or retirement account with a foreign employer, a joint account with a spouse who is not a US person, and accounts the client can sign on for at work.

Travel days and residency records for expat clients

Travel days and residency records are the proof of where the client was during the year. They support one of two tests in Publication 54 for the foreign earned income exclusion: the physical presence test, which counts full days abroad, and the bona fide residence test, which looks at residence in a foreign country for a whole tax year.

Publication 54 defines the physical presence test as being "physically present in a foreign country (or countries) for 330 full days during a period of 12 consecutive months," and says the days need not be consecutive. The Instructions for Form 2555 (2025) say the 12-month period on the form must include 365 days, part of which falls in 2025. Counting to 330 needs a day-by-day record.

For the bona fide residence test, Publication 54 says the client must be a bona fide resident of a foreign country for an uninterrupted period that includes an entire tax year, and that living abroad for one year does not by itself qualify. The test is limited to US citizens and to resident aliens who are citizens or nationals of a treaty country.

Records that help reconstruct the year:

• A travel log with each departure and arrival date, the countries and the purpose of US visits.
• Flight confirmations and boarding passes, which pin down dates when the log is unclear.
• Passport stamps or entry records, where the client's country of residence keeps them.
• A residence permit or visa, and its validity dates.
• A foreign lease or property deed, and proof of local tax residence such as the foreign tax return.

Ask for the log in a simple table: date left, date arrived, from, to. A calendar of trips is much easier to count than a folder of airline emails, and it shows gaps the client may need to fill.

Housing costs and foreign tax paid by expat clients

Housing costs and foreign tax paid are two separate sets of receipts. Housing costs, such as rent and utilities, support the foreign housing exclusion or deduction on Form 2555. Foreign tax receipts and the foreign return support the foreign tax credit on Form 1116. Both need the local-currency amount and the date paid.

The Instructions for Form 2555 (2025) say housing expenses include "rent, utilities (other than telephone charges), real and personal property insurance," and also nonrefundable lease fees, furniture rental, residential parking and household repairs. They exclude deductible interest and taxes, the cost of buying or improving a house, mortgage principal, depreciation, domestic labor, pay television and buying furniture. A request that names the included items gets cleaner answers than "send your housing costs."

For foreign tax, IRS Publication 514 (Foreign Tax Credit for Individuals, for use in preparing 2025 returns) lists the records to keep in case the IRS later asks to verify foreign taxes on Form 1116:

• A receipt for each foreign tax payment.
• The foreign tax return, if the credit is claimed for taxes accrued.
• Any payee statement, such as a Form 1099-DIV or 1099-INT, that shows foreign tax.

Publication 514 adds that the receipt or return kept as proof should be an original, a duplicate original, or a certified or authenticated copy, with a certified translation if it is in a foreign language. That is worth telling a client before they send a phone photo of a summary page.

An example expat checklist

This is a filled-in example for a fictional client living in a fictional country. Issuers, amounts and rates are examples only.

Which exchange rate goes on expat tax documents?

The exchange rate on expat tax documents depends on what the amount is for. The IRS says to translate income and expenses at the rate in effect when each is received or paid, and it publishes yearly average rates. Form 8938 values use the year-end rate. Write the rate and its source beside every amount.

The IRS page on foreign currency and currency exchange rates (last reviewed 22 May 2026) says amounts on a US return must be in US dollars and to "use the exchange rate prevailing when you receive, pay, or accrue the item." The IRS page on yearly average currency exchange rates (last reviewed 17 September 2026) lists averages through 2025, says the IRS has no official rate, and says it accepts any posted exchange rate used consistently.

Other forms have their own rules:

• Form 1116. The Instructions for Form 1116 (2025) say that when a credit is taken for taxes paid, the rate is the one in effect on the day the foreign tax was paid; for accrued taxes, it is generally the average rate for the tax year the taxes relate to. They ask for a detailed explanation of how the conversion rate was figured.
• Form 8938. The Instructions for Form 8938 say to use the U.S. Treasury Bureau of the Fiscal Service rate in most cases, and the rate on the last day of the tax year for the threshold test.

The checklist's job is not to choose the rate. It is to make sure every amount arrives with its currency, its date and room for the preparer to record the rate and its source. A spreadsheet that holds the local amount and the dollar amount in separate columns keeps that trail; the post on how foreign currency receipts should appear in Excel shows that layout.

Expat documents that arrive on a foreign tax year

Expat documents that arrive on a foreign tax year cover a period that does not match the US calendar year. When a client's foreign tax year ends in, say, April or June, one foreign return straddles two US years. Note the period each document covers on the checklist, and expect to need two foreign returns to cover one US year.

IRS Publication 514 says "tax year" means the year for which the US return is filed, not the year of the foreign return. It also says that for a taxpayer on the accrual basis, foreign taxes generally accrue at the end of the foreign tax year the foreign return covers. How that applies to a particular client is for the preparer to work out. The checklist only needs to record which months each foreign document covers.

The timing problem is practical too. A foreign return for a year that ends in mid-2026 may not be filed or assessed until well after the US filing season starts. Publication 54 says US citizens and residents living abroad on the regular due date get an automatic two-month extension to file, to June 15, 2026 for a calendar-year 2025 return, and that a further four months, to October 15, 2026, can generally be requested. It also says those additional four months are not an extension of time to pay. Record on the checklist when each foreign document is expected, so the firm can plan around it.

Some foreign documents have no US equivalent at all: a local social insurance statement, a church tax notice, or a pension statement with no US counterpart. List them anyway, labelled with what they are and what they show, and let the preparer decide what they mean.

Schema CPA keeps one file per client however the papers arrive, whether as email attachments or phone photos, and drafts a reminder listing what is still outstanding for the firm to review and send; the client tracker demo shows that view. For other clients with unusual paperwork, the household employee tax checklist covers families who pay a nanny, and the estate and trust tax organizer covers fiduciary returns.