Help to Save accounts and the US return

Is a Help to Save account a foreign financial account for the FBAR

In our view, yes. HMRC runs the scheme, but the account itself is opened and kept by National Savings and Investments, which HMRC names as the sole account provider. It is a sterling savings account in one person's name, maintained in the UK, and that is a financial account located outside the United States.

HMRC's technical manual says in HSTM03100 (opens the official HMRC page in a new tab) that NS&I has been chosen as the current sole provider of Help to Save accounts. The FBAR instructions at FinCEN (opens the official FinCEN page in a new tab) define a financial account to include a savings or deposit account maintained with a financial institution, or with another person performing the services of one, and a foreign financial account as one located outside the United States. A Help to Save account held with NS&I meets both parts of that definition.

Some readers ask whether an account backed by a government falls outside the report. The instructions do contain an exception for governmental entities, but it covers foreign accounts belonging to a US governmental entity. It says nothing about a private saver's account with a state-run savings bank abroad. FinCEN has not named Help to Save, so this is our reading, consistent with how we treat Premium Bonds and Junior ISAs.

How a Help to Save account counts towards the FBAR threshold

Take the highest balance the account reached in the calendar year and add it to the highest balances of every other foreign account you hold. If the total exceeds $10,000 at any time in the year, every account goes on the report, the Help to Save account included, however small it is.

GOV.UK's page on Help to Save (opens the official GOV.UK page in a new tab) caps what you can pay in each calendar month, so the account on its own grows slowly. The point most people miss is where the bonus lands. The page on what you will get (opens the official GOV.UK page in a new tab) says the bonus is paid into your bank account, not into the Help to Save account. Withdrawals also go only to that nominated account. For the FBAR, the bonus therefore raises the peak of your current account, while the Help to Save balance shows only what you paid in.

If the nominated account is a UK bank account, it is already a foreign account on the report. Money withdrawn from the Help to Save account and sitting in the current account can count in both peaks, which FinCEN's method expects. Our post on the FBAR maximum value and exchange rate explains the conversion at the Treasury's year-end rate.

• Help to Save account: its highest balance in January to December
• Nominated bank account: its highest balance, including any bonus paid in
• Every other UK current, savings, ISA and pension account you hold
• Accounts closed during the year, at their highest value while open

Does Help to Save go on Form 8938

Only if you have a US return to file and your foreign assets pass that form's much higher threshold. For tax year 2025, a US person living abroad and not filing jointly files when specified foreign financial assets exceed $200,000 at year end or $300,000 at any time. Most people who qualify for Help to Save will be well below that.

The Instructions for Form 8938 (opens the official IRS page in a new tab) say that if you do not have to file an income tax return for the year, you do not have to file Form 8938, whatever your assets. They define a financial account as a depository or custodial account maintained by a foreign financial institution. On the cautious reading, a Help to Save account with NS&I is a depository account of that kind and would be listed if the form were due. Our page on Form 8938 explains the form, and the FinCEN Form 114 page covers the FBAR itself.

HMRC publishes a list of tax-favoured UK accounts that institutions treat as excluded from exchange of information reporting. It names ISAs, Junior ISAs and Child Trust Funds, and it does not mention Help to Save. Whether NS&I reports these accounts is a matter for NS&I and HMRC. It changes nothing about your own FBAR or Form 8938.

Is the Help to Save bonus taxable in the US

The honest answer is that the IRS has not addressed it. The UK treats the bonus as tax-free, and the United States taxes its citizens on worldwide income without adopting UK exemptions as a matter of course. We review the bonus on the facts of each case rather than treat either answer as settled.

HMRC's manual at HSTM06000 (opens the official HMRC page in a new tab) says the government bonus is tax-free and does not count as savings income for UK income tax. That is a statement of UK law. The IRS says on its page for US citizens and resident aliens abroad (opens the official IRS page in a new tab) that you are subject to tax on worldwide income from all sources, and it has published nothing that names Help to Save. A UK exemption does not settle the US position either way.

Two practical points follow. First, because the UK charges no tax on the bonus, there is no UK tax to claim as a foreign tax credit against any US tax on it. Second, if NS&I credits any interest to the account, check your statements for it, since interest from a UK account is generally income on a US return. For a household on Universal Credit, the amounts involved are usually small, and the larger question is often whether a return is due at all.

Do Americans on a low income have to file a US return

Often yes, because the test is gross income against a threshold for your filing status. For tax year 2025, a single filer under 65 files once gross income reaches $15,750, and a person who is married filing separately files at $5, the usual status for a US citizen married to someone who is not American.

The thresholds are set out in Publication 501 (opens the official IRS page in a new tab). A part-time wage that qualifies someone for Universal Credit can still be enough to require a return, particularly for a married person filing separately. Our post Do Americans in the UK have to file if they earn little? works through the thresholds, what counts towards gross income, and why filing below the threshold can sometimes still be worthwhile.

The FBAR is a separate question with its own test. FinCEN looks only at the value of your foreign accounts, so a person with no return to file can still owe an FBAR. The reverse is common too: plenty of households on Help to Save never reach the FBAR threshold, yet still need a Form 1040 because of their earnings and filing status.

How a part-time worker in Sheffield puts it together

Take a US citizen working part-time in Sheffield, married to a British husband and claiming Universal Credit as a couple. Each partner opens their own Help to Save account, as GOV.UK requires, with bonuses paid into her UK current account. Her husband is not a US person and has no US reporting.

Each January she lists her accounts: the Help to Save account, her current account, a joint savings account with her husband at its full value, and an old cash ISA. She takes each one's highest balance for the calendar year, converts it, and adds them. In a year the total exceeds $10,000, she files one FBAR listing all four by 15 April, extended automatically to 15 October. In the year the first bonus arrives, its effect shows in the current account's peak.

Separately, she checks whether her earnings require a return as married filing separately. If they do, she reports her wages and any interest, answers the foreign account question on the return accurately, and has the bonus reviewed before deciding how it is treated. Form 8938 does not arise at her level of assets. We prepare this through our foreign income and FBAR reporting service and individual tax return preparation.

• Confirm your US status and that you hold a Social Security number
• Download NS&I statements for each calendar year the account was open
• Note the date and amount of each bonus and the account it reached
• Record each UK account's highest balance for January to December
• Check the filing threshold for your status before deciding on a return
• Keep five years of records for each FBAR you file

What happens when a Help to Save account ends

The account closes four years after it opens, and GOV.UK says you cannot reopen it or open another. You keep the money. For the FBAR, the account is reported for each calendar year it was open, including the year it closed, at its highest value while open.

Because the scheme runs for four years from the opening date, the account years rarely match calendar years, and the second bonus may fall in a different FBAR year from the first. Closing early means missing the next bonus, according to GOV.UK, so a saver who closes in the third year still reports the account for that year. Once the account has closed and the money has moved, only the bank account that received it remains on future reports.

If earlier years were missed, settle the whole position before filing anything. Late FBARs can be filed with an explanation, as our post on late FBARs explains, and where returns were also missed and conduct was non-wilful, our streamlined filing service brings both up to date. For the wider rules on which UK accounts count, return to the guide to FBAR and FATCA for UK residents.