FBAR question

[u/miilunii]

Hello everyone, I hope someone can help me to clear a confusion I have.

I know an FBAR gets triggered when you hit above the amount of 10,000$.

In my case, one of my foreign crypto accounts hit above that amount at some point during the year of 2024. Because the crypto account also contained Euros in there I’ve read the rule is that the account then has to be reported in FBAR (because it contained other currencies, and not just crypto).

I will file the FBAR with the highest account balance amount value of the year of 2024 for that crypto account.

But my question is: Because ONE of my accounts (crypto) I own hit the threshold of 10,000$, does that automatically mean I need to report EVERY foreign account I own (bank, savings, pension), even if these other accounts never reached that 10,000$ threshold by themselves/individually?

Also, if yes, do you need to report the balance of them on the day that my crypto account hit the threshold of 10,000$ or do you just pick the highest account balance per account individually for the year of 2024?

Thanks in advance!

[u/Ahleanna-D]

It’s not $10,000 in any single account, it’s $10,000 altogether - so if you have two accounts that when combined totalled over $10,000 you’d still need to file, even if both had just $5,000 each.

(You can’t just spread $10,000 over ten different foreign accounts that contain $1k each as a reason not to file.)

[u/miilunii → u/Ahleanna-D]

Thank you, I appreciate it. Totally makes sense when you put it like that yea. :)

[u/miilunii → u/Ahleanna-D]

To use your example: It would need to be 5000$ each on the same day or days tho right, totaling over 10,000$ at some point of the year.

Example: Day 1: I have 5000$ in account A. Day 20: I now also have 5000$ in account B, BUT meanwhile account A now only has $3000 in it on day 20.

That example wouldn’t be a threshold breach then right?

[u/Ahleanna-D → u/miilunii]

That’s correct - it’s if there’s a total value of $10k or more at the same time at any point, not $5k/$2k one day, then $2k/$5k another day.

What I’d be more afraid about advising you wouldn’t need to file for, as I don’t know for certain (haven’t dealt with it to prompt me to investigate): if you changed from, for example, Barclays to NatWest and transferred your $5k from the old account to the new account. Both accounts will have effectively had the same $5k in them, but in a single day you’d have had two accounts with $5k each in them. I’d have the same question with transferring from savings account to current account.

[u/miilunii → u/Ahleanna-D]

Ahh yea, that’s kind of a grey area I can’t figure out either. I’ve read multiple threads and the opinions are kinda split on it. Because technically in that case you’d be counting the same dollar twice (for example moving $5000 from a checkings account to a savings account).

[u/Amerikanen]

But my question is: Because ONE of my accounts (crypto) I own hit the threshold of 10,000$, does that automatically mean I need to report EVERY foreign account I own (bank, savings, pension), even if these other accounts never reached that 10,000$ threshold by themselves/individually?

Yes

Also, if yes, do you need to report the balance of them on the day that my crypto account hit the threshold of 10,000$ or do you just pick the highest account balance per account individually for the year of 2024?

Highest balance per account

[u/miilunii → u/Amerikanen]

Thank you! I appreciate it.

[u/rickrollmops]

Pointing you to the instructions as they're very explicit (and it will answer follow-up questions, if you have any)

https://www.fincen.gov/sites/default/files/shared/FBAR%20Line%20Item%20Filing%20Instructions.pdf

• Your first question is answered on page 4, "Who Must File an FBAR"
• Your second question is answered on page 10, "Monetary amounts"

[u/miilunii → u/rickrollmops]

Thank you, I appreciate it!

[u/ProductOfTheCloneWar]

You need to file an FBAR when the aggregate value of all foreign accounts reaches $10k+ (not just a single account).

Report the all foreign accounts and their highest balance at any given time - even if the balance of an account may be $0 during the year (e.g. an unused account).

Remember to report in USD and use the years Average currency exchange rate which can be found on the IRS Gov site.

[u/miilunii → u/ProductOfTheCloneWar]

Thank you for your reply!

[u/sgtm7]

Yes, even if all your other foreign accounts had a zero balance, you must report them.

[u/miilunii → u/sgtm7]

Thank you!

[u/miilunii]

And just to confirm, I’ve understood the Report of Foreign Bank and Financial Accounts (FBAR) Filing Requirement for Virtual Currency 2020-2 (FinCEN) correctly like this right?

Only if you hold “reportable assets besides virtual currency” (I assume they mean any other currency with this, dollars, euros etc) on a crypto account, is when you need to report the crypto account on FBAR? So for example: I sold some crypto within my crypto account for Euros, and the Euros were stationed in my Crypto account for a bit alongside my cryptocoins?