I have had this debate with the firm (large global) preparing my taxes and heard the same thing with respect to Form 8938 and reporting the maximum aggregate value of all assets. I was told "it is the sum of the max of each account. Don't worry about it, it is only informational." (also this is how their software is coded)
In disbelief, I contacted the IRS (Help Line – Regulatory Law) for clarification. I was advised that the intent of the line was to report the maximum aggregated value of all assets for the period and NOT the sum of the maximums for each account. So MAX (Acct 1 + 2+ 3) during the period and not MAX 1 + MAX 2 +MAX 3.
A rather indigent IRS advisor said... "You are over thinking this. The aggregate max value is the max value of all accounts at a single point in the year. It is not the sum of the maximums of each account. That would be stupid." He further advised my tax firm correct their software and call the IRS and that maybe I should find another company to prepare my taxes.
What about clarifying the instructions for this form? .... The advisor said that clarified instructions were not required as the intent is clear for the maximum total value of assets held were to be reported and reporting the sum of the maximums may overstate this amount.
Incidentally, I suspect the logic for this line is confused by the foreign asset reporting requirement limit which is if the sum of the maximum (MAX1 + MAX2 + MAX3) for each account is >10K.
Since the software could not changed and the value overridden, we added a statement that indicated the correct value. Maybe next year, the software will be corrected.
