Neillc37

So I was sure. After searching I saw references to changes in 2014 so I became unsure again. Like anything with the tax code it becomes out of date the moment you look at it.
Later you state that you policy was to file anyway but you said you don't have to file under the definition of aggregate from the form. So you were not taking the safe position.

I think this is the place it's defined:

31 CFR 1010.306 - Filing of reports.

(c) Reports required to be filed by § 1010.350 shall be filed with the Commissioner of Internal Revenue on or before June 30 of each calendar year with respect to foreign financial accounts exceeding $10,000 maintained during the previous calendar year.

So incredibly vague.

scot47

Strewth. No wonder tax accountants are strange. Dealing with this sort of stuff would drive me back to drink !

MidAtlantic

Obviously written to ensure that tax attorneys make some money.

MidAtlantic

oh!

Neillc37

I think it's been updated but I can't find it yet. Too hard to find anything.

Neillc37

It amazed me that the US is in all out war to extract money from anything foreign that's not tax compliant but the rules are full of grey areas. Do you need to file 3520 for this or that pension etc.

Sec 1291 that describes the tax on foreign mutual funds is incredibly complex. You encode this tax into for 8621. When I did this in software I found cases that were undefined wrt distributing the excess distributions among dividends. I had to invent something reasonable to do in at least one case.
When I filled my return (400+ form 8621s) the IRS agent told me the numbers were wrong. We pointed her to a completely different place in CFR (26 CFR 1.1291-9 - Deemed dividend election) describing the rule we used.
She agreed we were right. Said that they couldn't do the calculation I had done in their software. She said they did a back of the envelope calc to check my numbers and they then just accepted my return.
Total joke when you think about it. Might be OK if they were not enforcing this stuff with an iron fist.

mrken30

and don't forget about the new FATCA requirements https://www.irs.gov/Businesses/Corpo...or-Individuals

mrken30

But the money can be reported in two different accounts on the same day, therefore it may appear to be two different lots of money.

Remember it takes minutes to transfer money in the UK not days.

lansbury

Start of business day Account A $6000, Account B $1000 aggregate $7000

transfer $5000 from a to b

Close of business day Account A $1000, Account B $6000 aggregate $7000

mrken30

Do all banks report the account daily total end of the day? Do some report the account daily total at the start of the business day?

Another example. I deposit $5000 from my checking into savings, it appears immediately in my savings account , however it takes 3 days for it to be deducted from my checking account. For those 3 days it appears I have $10,000 , but in reality it is the same $5000. This mostly happens with online savings accounts , so they pay interest from day of deposit.

durham_lad

This is exactly the approach I take.

I make a pdf copy of each monthly bank statement and there is one balance listed for each day of the month. It is the highest daily balance of each account that I report. I only have 2 accounts, checking and savings. I transfer money between the accounts all the time and those transfers happen same day. I don't record the highest value an account gets to during the day for FBAR, I rely on the bank statements.

lansbury

When I do a transfer from one account to another either with NatWest in the UK checking to savings, or OnPoint here checking to savings, the transfer is deducted from one and deposited in the other account immediately. Banks normally report the balance for the day at end of business.

mrken30

My Barclays online savings account takes a while to deduct the money. The opposite happens with citibank, the money disappears for 3 days.

samiam1066

Thanks to all for excellent information.