For those wondering, fitting 38's on an XJ is an experience. It really isnt too bad if you have some decent metal working skills, but this is about the max I could get without relocating the battery. Hopefully these pics and images can help someone else do this as well.
Approximate fender trimming (I had already trimmed for 35's, so this is in addition to that, and I also had to cut more as I kept testing)
I had some issues with the tire hitting at the rear, even with the stretch I do have on the front axle. A little bit of BFH massaging:
After that it was clearancing the front inner fenders on both sides. This was about the max I could get without relocating the battery. I did have to trim my battery tray and space it up about 1/4".
Since my tires are worn down I wanted to make sure I had some extra clearance for when I get new tires.
For the driver side, I have already relocated washer bottle, and run a cowl intake so really nothing to get in the way on this side.
And with that I now have full steer at max flex, without any rubbing.