File FATCA, possibly FBAR soon. The IRS tax forum this summer, announced that the foreign wallet is considered an asset. There are proposed laws to make it part of the foreign accounting laws. The asset vs account is the key here. This means:
FATCA - Form 8938 & Instructions for Form 8938 are filed with the IRS if thresholds are met.
Who Must File
Unless an exception applies, you must file Form 8938 if you are a Specified Person, l that has an interest in specified foreign financial assets and the value of those assets is more than the applicable reporting threshold.
As to the FBAR, this is the proposal to make the FBAR necessary and should be passing soon, Notice-Virtual Currency Reporting on the FBAR 123020.pdf.
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