Valuation of UK DC pension plan for FBAR/8938

As a US citizen living in UK, I have a few defined contribution pension plans, for which I receive an annual summary giving a plan value.

I understand these plans must be included on the FBAR and Form 8938.  Since the date of the valuation is an arbitrary date during the year, how can I determine the value as of 31st Dec or the maximum value during the year?

Reading the IRS instructions for 8938, it states :

Valuing Interests in Foreign Estates, Foreign Pension Plans, and Foreign Deferred Compensation Plans

If you have an interest in a foreign estate, foreign pension plan, or foreign deferred compensation plan, the maximum value of your interest is the fair market value of your beneficial interest in the assets of the estate, pension plan, or deferred compensation plan as of the last day of the tax year. If you do not know or have reason to know based on readily accessible information the fair market value as of the last day of the tax year, the maximum value is the fair market value, determined as of the last day of the tax year, of the cash and other property distributed during the tax year to you as a beneficiary or participant. If you received no distributions during the tax year and do not know or have reason to know based on readily accessible information the fair market value of your interest as of the last day of the tax year, use a value of zero as the maximum value of the asset.

This implies that I should put a value of zero, since I do not explicitly know the value of the plans as of 31st December. Is this correct?

As a US citizen living in UK, I have a few defined contribution pension plans, for which I receive an annual summary giving a plan value.

I understand these plans must be included on the FBAR and Form 8938.  Since the date of the valuation is an arbitrary date during the year, how can I determine the value as of 31st Dec or the maximum value during the year?

Do you take distributions?

Thanks for your reply,

No - I am at least 6 years short of my planned retirement age.

I have amended my original question with information I discovered on the IRS form 8938 instruction.

So what I do for the FBAR is to check the maximum value unknown box. Like you, I get an annual statement, but who knows if the value of the fund is more or less from that statement date. Clicking the max value unknown is the best answer.

From an 8938 perspective, I check the $0 - $50k box. I too take no distribution and have no idea what the FMV is on December 31st. I will be purchasing an annuity this year, so in this case, I will list the actual value of the pension fund on the FBAR, (which will be closed) and check the relevant box on the 8938. The annuity income will be fixed and easily listed on FBAR and checked in the $0 - $50k box of 8938, (the annuity income will be less then $50k a year).

The value of $0 is actually used in determining the filing threshold. Even without the pension fund, i'd still need to file an 8938, BUT if if your foreign assets were otherwise, then you may not have to file the 8938.

For my pensions, I look-up their values on 31 Dec and take a screen shot for my records.  In years where I've forgotten to do that, I just email the pension providers asking for the value as of the end of the year.

I guess everyone adopts a different position here!

I receive 4 statements a year for my SIPP and I simply take the highest quarterly value - it's informational anyway and my view is that as long as I am being honest ( ) and rational and can support my disclosure, I'm not going to lose sleep over it. Surely the IRS have better things to do than check the accuracy of an informational disclosure? - maybe like processing the millions of paper tax returns (including mine form 2020!) that are probably sitting in a trailer gathering dust somewhere in the Texas desert.