@tbudd , I agree that
(a) FBAR instructions on page 10 may lead to transfers between accounts being counted twice and seems kind of silly for purposes of determining threshold to report
(b) Similar issue exists for FATCA threshold determination
However, consider that your reporting of the accounts and values are matched against reporting by the Foreign banks/financial institutions ( and they probably report both highest value and end-of-year amounts ). Also while the report is not a taxable event, deliberate ignore of the requirement can attract odious fines. Hence I generally suggest, even when in doubt, just report and thus not attract any IRS/US-Treasury attention.
IMOH
Is there more I can do for you ?
