A Sukanya Samriddhi Yojana account you hold for your daughter becomes reportable on your FBAR and FATCA filings the moment you become a US tax resident, and every year's interest gets taxed on your US return in full, with no credit for Indian tax, because India exempts that interest entirely. Most parents never think of a child's college fund as a foreign asset. That's exactly what trips them up.
What the IRS wants from your Sukanya Samriddhi account
You already know the drill for your own accounts. FBAR and FATCA don't care whose name sits on the account, only whether you have a financial interest in it or signature authority over it. As guardian on your daughter's Sukanya Samriddhi account, you almost always have one of the two.
FBAR: the $10,000 trip wire
FBAR (FinCEN Form 114) applies once your aggregate foreign accounts cross $10,000 at any single point in the year, not on average and not just what you remit home. If your daughter's account alone gets you there, combined with an NRE or NRO account, you file.
The form goes to FinCEN's e-filing system, not the IRS. It's due April 15, automatically extended to October 15.
Form 8938: FATCA's separate, lower threshold
Form 8938 is a different filing, attached to your 1040, with its own thresholds. Living in the US and filing single, you cross it at $50,000 at year-end or $75,000 at any point; married filing jointly doubles both figures.
Filing one form never covers the other. Your broader FATCA obligations don't shrink just because this account is small.
| FBAR (FinCEN Form 114) | Form 8938 (FATCA) | |
|---|---|---|
| Filed with | FinCEN, not the IRS | IRS, attached to your Form 1040 |
| Threshold, single, living in the US | $10,000 aggregate, at any point in the year | $50,000 at year-end, or $75,000 at any point |
| Threshold, married filing jointly, living in the US | Same $10,000, no joint doubling | $100,000 at year-end, or $150,000 at any point |
| Deadline | April 15, automatically extended to October 15 | April 15, filed with your return |
Why the interest is taxed every year, with nothing to credit
India treats Sukanya Samriddhi Yojana interest as fully exempt under Section 10 of the Income Tax Act. That exemption means nothing on your US return.
The US taxes worldwide income regardless of what the source country decides to exempt. This account's interest is ordinary income the year it's credited, not the year you eventually withdraw it.
Not a PFIC, so no Form 8621
A PFIC is a foreign fund or company earning mostly passive income, and Indian equity and debt mutual funds usually qualify. Sukanya Samriddhi doesn't. It's a government savings scheme with no underlying securities, so it fails the PFIC test, and Form 8621 never enters the picture for this specific account.
That's one less filing, not one less obligation. You still report the account and its interest every year; you just skip the PFIC machinery your Indian mutual funds might already need.
No foreign tax credit offsets any of it. A credit requires actual foreign tax paid, and India's exemption leaves nothing to credit. Compare that with an Indian fixed deposit, where TDS at least gives you something to claim on Form 1116.
The same exemption mismatch shows up with PPF, EPF and NPS. A scheme India built to be tax-free simply doesn't carry that status across the border.
Who this applies to
This applies once you're a US person: a citizen, a green card holder, or someone who has crossed the Substantial Presence Test. If you're still filing Form 1040-NR as a nonresident alien, none of this reaches you yet, though it starts the instant you cross that line.
It applies whether you're the registered guardian on the account or simply hold signing authority, which many NRI parents keep even after a grandparent handles the day-to-day deposits. It doesn't matter whether your daughter has become a US person herself. The obligation sits with you because of your own interest in the account.
Whether the account can keep running in India is a separate question from whether you must report it, and the guidance on that point is genuinely mixed. Confirm the account's actual status directly with the post office or bank holding it once residency changes.
What to do about it
Work through it in this order:
- Add the account to your FBAR the year your combined foreign balances first cross $10,000, using whichever balance figure your filing software asks for.
- Check the Form 8938 threshold for your filing status and where you live, and include the account if you're over it.
- Report each year's accrued interest as ordinary income on Schedule B, converted using the Treasury's yearly average exchange rate.
- Skip Form 1116 for this specific income. There's no Indian tax paid on it to credit.
- If you've held the account for years without reporting it, look at the FBAR streamlined filing procedures before you file this year's return. Catching up quietly, one year at a time, is the wrong order to do it in.
Where NRI parents get this wrong
It's not really my asset. In conversations with parents in exactly this position, the Sukanya Samriddhi account is the one that almost never comes up first. They list a 401(k), a brokerage account, an EPF balance, all without prompting.
A daughter's account gets left out entirely, not from hiding it, but because it never registers as a foreign asset of their own. One client only flagged his after I asked directly, alongside mutual funds he'd held for fifteen years without realizing they were PFICs.
It's tax-free, so the US can't touch it. The exemption is real in India. It stops at the border.
The US taxes the interest as ordinary income regardless of what India decides to exempt. That gap is the whole reason this account needs its own line of thinking rather than a shrug.
Filing FBAR must mean I'm already in trouble. Filing late is a problem, but filing correctly, starting now, is not. Most parents in this position qualify for a non-willful path that fixes past years without the penalties willful non-disclosure carries.
If you haven't reported this account yet, don't fold it quietly into this year's return and hope nobody asks about the years before it. Talk to whoever handles your cross-border filing about the streamlined path first.
That conversation costs far less than an IRS notice later. I'd rather field a question about this account now than one about a PFIC you didn't know you had.
Frequently asked questions
Is Sukanya Samriddhi Yojana interest taxable in the US if it's exempt in India?
Yes. India's exemption under Section 10 has no bearing on your US return. The interest counts as ordinary income the year it accrues, reported on Schedule B, with no foreign tax credit available since no Indian tax was paid on it.
Can NRIs continue contributing to a Sukanya Samriddhi account after moving to the US?
The scheme is built for resident Indian citizens, and continuing contributions gets complicated once the guardian or the girl child becomes non-resident. What happens to an existing account varies by branch and circular interpretation, so confirm directly with the post office or bank holding it.
Does FBAR apply to a Sukanya Samriddhi account opened for my daughter?
Yes, if you have a financial interest in it or signature authority over it and your combined foreign accounts cross $10,000 at any point in the year. Guardianship alone is usually enough to create that authority.
Is a Sukanya Samriddhi account treated as a PFIC?
No. PFIC status applies to foreign funds and companies earning passive income, and Sukanya Samriddhi is a government savings scheme, not a fund. You still report the account and its interest; you just skip Form 8621.
Can an OCI cardholder open a Sukanya Samriddhi account for their daughter?
No. The scheme requires the girl child to be a resident Indian citizen, and OCI status doesn't meet that bar. A parent who holds OCI status can typically still serve as guardian on an account opened while the daughter was a resident citizen.