I started to look into FBAR report filing requirements (FinCEN Report 114) and thought I would share my preliminary thoughts.
A United States person, including a citizen, resident, corporation, partnership, limited liability company, trust and estate, must file an FBAR to report:
(1) a financial interest in or signature or other authority over at least one financial account located outside the United States if
(2) the aggregate value of those foreign financial accounts exceeded $10,000 at any time during the calendar year reported.
The report is due by April 15 following the calendar year reported.
You must file the FBAR electronically through the Financial Crimes Enforcement Network’s BSA E-Filing System. You don’t file the FBAR with your federal tax return.
There is a FinCEN website that makes this annual report relatively easy.
Here are a few things to look out for:
- If you have more than 10,000 USD aggregate you must report all foreign accounts.
I have one bank account opened by “accident” with a $0 balance and I am reporting this.
You may have to report all cryptocurrency accounts (regardless of balance). There is some info here about which account may qualify:
If you have a Transferwise account, you will likely need to report balances in any non-USD wallets. You can get the bank info by looking up your IBAN for each account and the IBAN lookup will tell you the address info and name for the “bank”. Transferwise customer support can also help with this. It is not clear whether each non-USD wallet needs to be reported separately. Technically they are different banks so maybe so, but from the US person standpoint you just have one relationship with Transferwise. You will need to make that determination on your own.
For GV investment fund. My initial read of the definition of “financial account” includes a securities account or a GV account. However, the IRS FBAR reference guide excludes private equity funds.
Example: Foreign hedge funds and private equity funds are not reportable on the FBAR. The FBAR
regulations issued by FinCEN on February 24, 2011 do not require the reporting of these funds at this time.
Additionally, if you hold interests in a company such as GV investment funds, this appears to qualify as a “Financial Interest” as defined by the law only if certain criteria are met. Based on definition of a “financial interest” there may be a basis to exclude reporting if you have only a small interest in the GV fund.
Thus it would appear the GV investment portion is not reportable on FBAR.
[Edited to correct my initial comment based on input from @jb4422 ]
Note for all of the above you must report the highest balance during the reporting year.
If anyone has a different opinion on any of this, would appreciate any input…
This is not intended as legal or accounting advice, so you should consult your own lawyer or tax professional. Each person’s situation will be unique.