Japan’s Foreign Asset Report (Kokugai Zaisan Chosho): When U.S. Bank, Brokerage, and 401(k) Accounts Top ¥50 Million After You Move Back (2026)

Many people who finish an assignment or a career in the U.S. and move back to Japan keep their U.S. bank and brokerage accounts, 401(k), or IRA. Once you are back and a Japanese resident, those U.S. assets can bring you into Japan’s foreign asset report, the kokugai zaisan chosho.

The report is filed by residents whose foreign assets total more than ¥50 million on December 31, and it is due June 30 of the following year. It is not a tax return, but whether you file it affects penalty tax if income from those assets is ever underreported, and failing to file can carry criminal penalties.

If you moved back during 2026, the test uses your values on December 31, 2026, and the report is due June 30, 2027. Year-end balances and the year-end exchange rate decide the result, so it is worth understanding the rules before December.

Key points

• If on December 31 you are a resident of Japan (other than a non-permanent resident) and your foreign assets total more than ¥50 million, file the report by June 30 of the following year.
• Non-permanent resident status applies only to people without Japanese nationality, so a Japanese national who moves back is tested starting December 31 of the year of return.
• Deposits and securities in U.S. bank and brokerage accounts are foreign assets. U.S. stocks held in a Japanese brokerage account, and foreign-currency deposits at a Japanese bank’s domestic branch, are not.
• Convert foreign-currency assets to yen at the December 31 telegraphic transfer buying rate (TTB) or a similar rate. For a defined contribution pension joined while working abroad, the NTA FAQ says you may use the surrender value payable if the plan were cancelled on December 31.
• Filing on time with the asset listed cuts the penalty tax on underreported income from that asset by an amount equal to 5% of the tax; not filing, or leaving the asset out, adds 5%.

What the foreign asset report is

The report lists the type, quantity, value, and location of assets you hold outside Japan, organized by type, use, and location, together with a summary sheet (gokeihyo). It is an information report; no tax is computed on it.

Separately, a Japanese resident who is not a non-permanent resident is taxed on all income arising in and outside Japan. Interest, dividends, and gains in your U.S. accounts belong on your Japanese income tax return regardless of the report.

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Who must file: the test starts in the year you return

The filer is a resident (excluding non-permanent residents) who holds foreign assets with a total value over ¥50 million on December 31 of the year. Residency is judged by your situation on December 31.

A non-permanent resident is a resident who does not have Japanese nationality and has had a domicile or residence in Japan for a total of five years or less in the past ten years. Japanese nationals can never be non-permanent residents, so if you return mid-year and are a resident on December 31, the test applies to that year.

Status on December 31	Foreign asset report
Japanese national resident, including returnees	File if foreign assets exceed ¥50 million
Resident without Japanese nationality who lived in Japan five years or less in the past ten (non-permanent resident)	Not required
Any other resident without Japanese nationality	File if foreign assets exceed ¥50 million
Nonresident of Japan (for example, still living in the U.S.)	Not required

Is it a foreign asset? How U.S. accounts are classified

Location is generally determined under the property-location rules of Japan’s inheritance tax law. For deposits and securities accounts, the NTA FAQ explains:

• Deposits: whether in yen or a foreign currency, location follows the office of the financial institution that took the deposit. A U.S. bank account is a foreign asset; a dollar deposit at a Japanese bank’s branch in Japan is not.
• Securities: if held in an account opened at a securities firm’s office, location follows that office. Stocks and funds in a U.S. brokerage account are foreign assets; U.S. stocks in an account at a Japanese brokerage are domestic assets.

Typical asset for returnees	Foreign asset?	How it is valued
U.S. bank deposits	Yes	December 31 balance, converted to yen
Stocks, ETFs, and funds in a U.S. brokerage account	Yes	December 31 market value, converted to yen
401(k), IRA, or other U.S. retirement account	FAQ Q31 addresses valuing a defined contribution pension joined abroad	Surrender value if cancelled on December 31 (per the FAQ)
A U.S. home or other real estate you kept	Yes	December 31 market value or estimated value, converted to yen
U.S. stocks in a Japanese brokerage account	No (domestic)	Not listed
Foreign-currency deposit at a Japanese bank’s domestic branch	No (domestic)	Not listed

Valuation and yen conversion

Report each asset at its fair market value (jika) on December 31, or at an estimated value (mitsumori kagaku) treated as equivalent. An estimated value is computed by a reasonable method based on the asset’s condition on December 31, such as its cost or comparable sale prices. Under NTA guidance, the estimated value of a deposit is the December 31 balance.

Convert foreign-currency assets at the December 31 exchange rate: specifically, the final TTB (telegraphic transfer buying rate) published that day by your financial institution, or a similar rate. The same dollar balance can land above or below ¥50 million depending on the year-end rate.

Valuing a 401(k) or IRA

NTA FAQ Q31 addresses a defined contribution pension you joined while working abroad and plan to receive as an annuity. It says that, as a right under an insurance or mutual aid system based on foreign law, you may report the surrender value that would be paid if the contract were cancelled on December 31, or a surrender value as of an earlier date in the year if the insurer has provided one.

The FAQ does not name the 401(k) or IRA, and it does not say how the account balance relates to the amount payable on cancellation, for example how U.S. tax or the early withdrawal penalty is treated. Confirm how it applies to your accounts with the tax office or a Japanese tax accountant.

Deadline, where to file, and how

Item	Rule
Test date	December 31 of the year
Threshold	Total value of foreign assets over ¥50 million
Deadline	June 30 of the following year (June 30, 2027 for 2026)
Where	The tax office for your address
Attachment	Summary sheet (kokugai zaisan chosho gokeihyo)
How	On paper, or electronically via e-Tax

Starting with the 2023 report, the deadline moved from March 15 to June 30 of the following year. It no longer matches the income tax return deadline, so either prepare it with your return or set a separate June schedule.

Penalty tax incentives and criminal penalties

Situation	Result
Filed on time, and the asset behind an income or inheritance tax underreporting was listed	Underpayment (or failure-to-file) penalty tax on that asset reduced by 5% of the tax
Not filed on time, or the asset was not listed	Penalty tax increased by 5% of the tax
Did not present documents on the acquisition, management, or disposal of foreign assets by the date the tax office set (no more than 60 days from the request), unless not at fault	No reduction; increase generally becomes 10%
Filed with false entries, or failed to file by the deadline without good reason	Up to one year of imprisonment or a fine of up to ¥500,000 (for failure to file, the penalty may be waived depending on circumstances)

A late report is still treated as filed on time for the reduction and increase rules if you submit it before receiving notice of a tax examination and not in anticipation of an assessment. If you realize you should have filed, file as soon as possible.

How it relates to the statement of assets and liabilities

Higher-income or wealthier taxpayers may also need a separate report, the statement of assets and liabilities (zaisan saimu chosho), also due June 30 of the following year. It is required if either applies:

• You must file an income tax return, your total income excluding retirement income exceeds ¥20 million, and on December 31 you hold assets worth ¥300 million or more or securities and similar assets worth ¥100 million or more.
• You are a resident holding assets worth ¥1 billion or more on December 31.

If you meet both tests, file both. On the statement of assets and liabilities, foreign assets need no detail other than their value; the detail goes on the foreign asset report.

Example: the year you move back

Example (hypothetical numbers): A, a Japanese national, moves back from the U.S. in August 2026 and holds these U.S. assets on December 31, 2026:

Asset	Value on December 31
U.S. bank deposit	$50,000
U.S. brokerage account (stocks and ETFs)	$200,000
401(k) (assumed value under the FAQ approach)	$150,000
Total	$400,000

• Year-end TTB of ¥145: $400,000 × 145 = ¥58 million. That exceeds ¥50 million, so A must file by June 30, 2027.
• Year-end TTB of ¥120: $400,000 × 120 = ¥48 million. Not over ¥50 million, so no filing is required.
• If the $200,000 of securities were held in a Japanese brokerage account instead: foreign assets are $200,000, or ¥29 million at ¥145, so no filing is required.

The same holdings can give different answers depending on the exchange rate and where each account is held. A simple list of balances and account locations before year-end makes the call easier.

FAQ

Do I need to file for the year I move back?

Yes, if on December 31 you are a resident other than a non-permanent resident and your foreign assets exceed ¥50 million that day. Japanese nationals are never non-permanent residents.

Do U.S. stocks at a Japanese brokerage count?

No. If the account was opened at an office in Japan, the stocks are domestic assets and are not included.

What if I file late?

If you file before a notice of tax examination and not in anticipation of an assessment, the report is treated as filed on time for the penalty tax reduction and increase rules. File as soon as you can.

Does filing the report create tax?

No. The report only lists assets. But a resident other than a non-permanent resident is taxed on worldwide income, so interest, dividends, and gains in U.S. accounts may need to go on your Japanese return.

What if I still hold U.S. citizenship or a green card?

U.S. reporting such as the FBAR or Form 8938 may continue alongside the Japanese report. See the related articles for the U.S. rules.

At CLT NY INC., an IRS Enrolled Agent helps people moving between the U.S. and Japan with the U.S. side of their taxes, including the final-year return and what to do with U.S. accounts and 401(k) plans, in English or Japanese. For preparing the Japanese foreign asset report itself, please consult a Japanese tax accountant or the tax office. Contact us.

Related articles

• Pre-Departure Checklist: What to Confirm Before Closing Your US Bank, Brokerage, and 401(k) Accounts
• Withdrawing a 401(k) or IRA After Returning to Japan: 30% Withholding and Relief Under the US-Japan Tax Treaty
• The Definitive Guide to Filing US Tax Returns (1040/1040NR) from Japan After Repatriation: Procedures, Payment, and Refund Methods
• Children Born in the U.S. Are U.S. Citizens: Filing Obligations That Follow Them to Japan and the Accidental American Problem
• Navigating the Strict State Taxes of New York and California: Residency Risks for Individuals Returning to Japan
• Filing Your Japanese Tax Return After Returning from the U.S.: How to Report U.S. Salary, Stocks, and Rental Income and Claim the Foreign Tax Credit

Sources: NTA No.7456 (who must file the foreign asset report); NTA Foreign Asset Report FAQ (June 2025); NTA leaflet on the foreign asset report; NTA interpretive circular on the foreign asset report and statement of assets and liabilities; e-Gov: the Japanese act governing the foreign asset report (Articles 5, 6, and 10); NTA No.7457 (who must file the statement of assets and liabilities); NTA: 2023 changes to both reports; NTA No.2010 (scope of taxable income). Information as of October 2026. This article provides general information and is not individual tax advice.