Gold bars and coins that you hold yourself are not a financial account, so they do not go on the FBAR, and a safe deposit box is not a financial account either. The answer changes when someone else holds the metal for you. The Internal Revenue Manual on the FBAR (opens the official IRS page in a new tab) says a reportable account relationship may exist where a foreign agency holds precious metals on deposit, and where a box provider can reach and dispose of what is inside on your instruction. A reportable metals account then counts towards the $10,000 aggregate threshold.
This post is for US citizens and green card holders in Britain who own sovereigns, Britannias or bullion, whether in a drawer, a bank box or a vault account. It extends our guide to FBAR and FATCA for UK residents on one narrow question, and covers the FBAR, Form 8938 and how a sale is taxed in each country. Digital holdings have their own post on crypto on the FBAR and Form 8938.
Is gold you hold yourself reportable on the FBAR
No. The FBAR covers financial accounts, and physical metal in your own possession is not one. The Internal Revenue Manual lists precious metals, precious stones and jewels held directly by the person among the things that are not financial accounts. Coins in a home safe or bars in a drawer stay off the report.
The FBAR rules start from the account, not the asset. FinCEN describes a financial account as a securities, brokerage, savings, demand, checking, deposit or other account maintained with a financial institution, or with another person performing the services of one, and the FinCEN page on reporting foreign accounts (opens the official FinCEN page in a new tab) is the primary source for the report itself. A gold coin is property. It becomes part of an FBAR question only when it sits inside a relationship with an institution that holds it for you.
The IRS comparison of Form 8938 and FBAR requirements (opens the official IRS page in a new tab) says the same thing in table form. Precious metals held directly are marked as not reportable on either the FBAR or Form 8938. The same table excludes foreign currency held directly, and personal property such as art, antiques, jewellery and other collectibles. A US person in Britain with a box of sovereigns and nothing else abroad has no FBAR to file because of them.
- Coins or bars kept at home: not a financial account
- Jewellery and gold heirlooms held by you: not a financial account
- Banknotes in pounds kept in a safe: foreign currency held directly, not reported
- Gold sitting in a UK platform or broker account as a fund or product: part of that account
Is a safe deposit box a financial account for the FBAR
Generally not. The Internal Revenue Manual lists a safety deposit box among the things that are not financial accounts, and the IRS answer on Form 8938 is the same. Even so, a reportable account may exist where the institution providing the box has access to the contents and can dispose of them on your instruction or by prior arrangement.
The ordinary bank box is a rented space. You hold the key or the code, the bank cannot open it without you, and it has no power to sell or pay away what is inside. That arrangement is outside the FBAR, whatever the contents are worth. The IRS FBAR guidance (opens the official IRS page in a new tab) and the manual both treat the box itself as a storage service rather than an account.
The exception is about control. Some storage arrangements let the provider take the contents out, sell them or deliver them to someone else when you ask, or under standing terms agreed at the outset. Once the provider can act on your instruction in that way, the box starts to look like an account the provider maintains for you, and the manual says a reportable account may exist. Read the terms rather than the product name.
When does a gold or bullion account become reportable
When a foreign institution or agent holds the metal, or money for buying it, on deposit for you. The Internal Revenue Manual says a reportable account relationship may exist where a foreign agency holds precious metals on deposit. It also treats an account with a person in the business of accepting deposits as a financial agency as a financial account.
Many people in Britain buy gold through a provider that stores it in a vault and shows the holding in an online account, with the option to sell or take delivery. Providers describe these holdings in different ways, including allocated and unallocated. The manual does not draw the line by those labels. It asks whether a foreign agency holds the metal on deposit for you, and the account terms are the best evidence. Where it does, we treat the account as reportable at its highest value in the year.
Other routes to gold exposure are already accounts. A commodity futures or options account is listed as a financial account in the FinCEN definition. A gold fund or exchange-traded product bought through a UK platform or ISA is covered by reporting that platform account, though the product itself may raise questions on Form 8621 (opens the official IRS page in a new tab). A cash balance left with a dealer between trades is held by someone accepting deposits for you.
- Vault holding a provider can sell or deliver on your instruction: treat as reportable
- Cash balance with a bullion dealer or platform: part of a reportable account
- Gold futures or options account outside the US: a financial account
- Gold fund or product inside a UK platform account or ISA: reported as part of that account
- Vault account you can operate for a parent under a power of attorney: possible signature authority
How does Form 8938 treat gold and gold certificates
Directly held gold is not a specified foreign financial asset, so it is neither listed nor counted towards the threshold. The IRS basic questions and answers on Form 8938 (opens the official IRS page in a new tab) say so in terms, and add that a safe deposit box is not a financial account. Gold certificates issued by a foreign person may be reportable.
The Form 8938 rules differ from the FBAR in structure. Form 8938 covers financial accounts maintained by a foreign financial institution and certain foreign assets held for investment outside an account, including any interest in a foreign entity. A certificate is a claim against its issuer, which is why the IRS treats a certificate from a foreign issuer differently from the metal itself. For a US person living abroad and not filing jointly, the form applies only once assets exceed $200,000 at year end or $300,000 at any time, as the Form 8938 instructions (opens the official IRS page in a new tab) set out.
Gold held through a company or trust is the case that changes most. The comparison table says that where real estate is held through a foreign entity, the entity is itself a specified foreign financial asset, and the same logic applies to metal held by a foreign company you own. A vault account with a UK provider is less clearly addressed for Form 8938, and depends on whether the provider is a foreign financial institution and what the account holds. Our post on what counts as a specified foreign financial asset covers the definitions.
- Coins or bars held directly, anywhere: not a specified foreign financial asset
- Safe deposit box: not a financial account
- Gold certificate issued by a foreign person: may be reportable
- Shares in a UK company that holds gold: the shares are reportable
How the rules apply to a mixed gold holding
Each holding is tested separately, and only the accounts go into the FBAR total. Physical coins in a box stay out. A vault account the provider can sell from on instruction goes in at its highest value. Ordinary bank accounts go in as usual, and the threshold is applied to everything together.
Take a US citizen employed as an engineer in Leeds. She keeps a tube of sovereigns in a rented box at her bank, which only she can open. She also holds gold bars through a UK provider that stores them in a vault and will sell them or ship them to her when she asks, and she has a current account and a cash ISA. The sovereigns are not reported. The vault account, the current account and the ISA are added together at their highest values, and if the total exceeds $10,000 all three go on her FBAR.
The vault account is valued like any other: the highest value in the calendar year, converted at the Treasury year-end rate, as our post on FBAR maximum value and the exchange rate explains. Keep the provider's statements showing the holding and its value. If she later moves the bars into her own box and closes the vault account, the account still appears on the FBAR for the year it was open. Our FinCEN Form 114 page describes the report.
How is a sale of gold taxed in the US and the UK
Differently in each country. On the US return, gain on gold, silver and platinum bullion or coins held more than a year is collectibles gain, taxed at a higher maximum rate than most long-term gains. In the UK, sovereigns minted from 1837 and Britannia gold coins are sterling currency and exempt from capital gains tax.
IRS Publication 550 (opens the official IRS page in a new tab) defines collectibles gain as gain from selling or trading a work of art, rug, antique, metal such as gold, silver and platinum bullion, gem, stamp, coin or alcoholic beverage held for more than one year. The reporting and filing requirements sit apart from this. Neither the FBAR nor Form 8938 creates any tax. A sale goes on the US return in the year it happens, whether or not the gold was ever on an information report.
HMRC's Capital Gains Manual on currency (opens the official HMRC page in a new tab) says coins count as currency only if they are legal tender when acquired or sold. Sovereigns from 1837 onwards and Britannias are exempt like all sterling, while non-sterling coins that are currency, such as Krugerrands, are chargeable. The mismatch matters. A US citizen selling sovereigns at a gain pays no UK tax, so there is no UK tax to credit against the US charge, and the whole US amount is usually payable.
We report sales of metal on the federal return as part of our individual tax return preparation, and we prepare the FBAR and Form 8938 from one schedule through our foreign income and FBAR reporting service. Send us your provider statements and box arrangements, and we will say which holdings belong on each report. The wider reporting rules are in our guide to FBAR and FATCA for UK residents.
General information, not advice. The right answer depends on your circumstances and the tax year concerned.
