Several account types should be taken into consideration when calculating if you met the USD 10,000 threshold for the year. You must include:
Foreign accounts that are not in your name but for which you have signature authority (i.e. you have control over them)
Foreign retirement accounts, pensions, etc.
Non-US-based cryptocurrency wallets
Foreign investment accounts holding assets such as stocks, mutual funds, insurance contracts
Example 1:
You are a US Citizen living and working in Taiwan. Your only foreign account is a Taiwanese bank account where you receive your local salary, and its highest balance last year was USD 5,000 because you always sent most of your paychecks back home to a US-based bank account. You do not have to submit an FBAR.
Example 2:
You are a US Citizen living and working in Taiwan. You have a Taiwanese bank account where you receive your local salary, and its highest balance last year was USD 4,000. You also opened a MaiCoin cryptocurrency trading account, and your MaiCoin wallet had a peak balance of USD 7,500 last year. These accounts combined were worth over USD10,000, so you DO need to file FBAR reports for them (even though no single account exceeded USD10,000).
Example 3:
You are a US citizen living in New York. Because you have family in Taiwan, you decide to open an account at the Land Bank of Taiwan New York branch and fund it with TWD1,000,000 (approx. USD31,000). Because the account is based within the United States, you don’t need to file an FBAR report for it.
Conversely, If you were to hold a balance over USD 10,000 at the Hong Kong branch of Bank of America, you would be required to file an FBAR for that account.
Exceptions
There are a few (rare) exceptions to the FBAR filing requirements. According to the IRS FBAR reference page, an account does not need to be reported if it is:
A Correspondent/Nostro account,
Owned by a governmental entity,
Owned by an international financial institution,
Maintained on a U.S. military banking facility,
Held in an individual retirement account (IRA) of which you’re an owner or beneficiary,
Held in a retirement plan of which you’re a participant or beneficiary, or
Part of a trust of which you’re a beneficiary is if a U.S. person (trust, trustee of the trust, or agent of the trust) files an FBAR reporting these accounts.
In general, almost all U.S. Persons who meet the threshold will need to file FBAR reports for their foreign accounts. Always consult a tax professional if you're uncertain about your FBAR obligations.
How can I get help with my FBAR?
In addition to standard tax filing and preparation services, the experts at Del Sol CPA and associates are more than happy to offer you assistance with filing a timely and compliant FBAR each year. If you have any questions or need guidance, please don’t hesitate to reach out to our bilingual team of trained tax professionals for answers.
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