This question is asked multiple times on reddit or even this forum and every time it has different answers. I talked to multiple CPA's and the answer is different as well.
If I held only crypto on foreign exchange and meet the threshold for both FBAR and FATCA 8938, am I required to file these forms?
The latest I found about FBAR is FinCEN Notice 2020-2 that says:
Currently, the Report of Foreign Bank and Financial Accounts (FBAR) regulations do not define a foreign account holding virtual currency as a type of reportable account. (See 31 CFR 1010.350(c)). For that reason, at this time, a foreign account holding virtual currency is not reportable on the FBAR (unless it is a reportable account under 31 C.F.R. 1010.350 because it holds reportable assets besides virtual currency).
That's pretty clear, no need to file FBAR if it's just crypto, however I still see here on the forum people saying that it is required to file?
As for FATCA 8938 I was not able to find any information specific to cryptocurrency. There's no guidance at all for 8938 specific to crypto.
What's your take on this?
The challenge I see here is I'm not able to find an exchange physical address that is required in those forms.
