We are married filing jointly and as per IRS provided info, the Form 8938 (FATCA) reporting threshold for us is "more than $150K in foreign assets at any time during the year" OR "more than $100k on the last day of the year".
Let us say, I have an Account A with $90K and another Account B with $5K. During the year I transfer $80K from Account A to Account B, so that at the end of year, we have (assuming no other inflow or outflow): Account A = $10K and Account B = $85K. So total value at the end of year= $10K + $85K = $95K (which is less than the 'end of the year' $100K requirement).
However, my question is how does the "more than $150K at any time during the year" test work. In the above example, did we cross the $150K threshold during the year. In my opinion, the answer is NO, but looking for informed opinion. Some folks have suggested that I should add the maximum value of each account ($90k + $85K) in the year to check against the during-the-year threshold. But this seems wrong to me as the amounts are being double-counted. What do you think?
