This is a phenomenally messed up part of tax reporting and Turbotax which appears does not have a good grip on the rules. Before panicking, remember that the 2025 IRS has been DOGE smashed like a punch-drunk heavy weight boxer. They aren't going to wasting time on obscurities when they can barely process the incoming coming flood of 2024 tax returns while Trump wants to put them permanently out of business. If we must reduce our standard of living so oligarchs don't have to pay income tax, at least this unwarranted invasion of privacy should be on the chopping block too. It's a new day bowing before the ERS, planned successor to the devastated IRS.
That said, "maximum value" is ambiguous. I will go with the FinCen definition which is stupid enough to satisfy the most extravagant interpretation remembering none of this is about taxation, only invasion of privacy and extra-territorial intimidation. Overstating maximum value does not generate overstated tax. Sigh, it does not generate a single penny in deductions or credits. Just your wasted time. They only want to look underneath your sk--t. Kinda of like TSA "checking" for financial matters. Most all, unless you have really big amounts it is doubtful that 99% of people caught in this external reporting hell are any serious threat of being big time money launderers.
"If the maximum account value of a single account or aggregate of the maximum account values of multiple accounts exceeds $10,000, an FBAR must be filed. An FBAR is not required to be filed if the person did not have $10,000 of maximum value or aggregate maximum value in foreign financial accounts at any time during the calendar year.
For United States persons with a financial interest in or signature authority over fewer than 25 accounts that are unable to determine if the aggregate maximum account values of the accounts exceeded $10,000 at any time during the calendar year, complete the appropriate Part II, III, IV, or V section for each of these accounts and check the “amount unknown” box, item 15a.
One final comment relevant to our times. To renounce US citizenship you have to show that you filed the last five years of Form 8938. (FinCen has its own threat mechanisms, but I don't think that is one of them). Congress wanted to go after people trying to get out of extraterritorial taxation which only the US and Liberia do. Play straight, nobody wants an unscheduled Central American stay.
