What if hypothetically you had a maximum of $5,100 in a foreign bank checking account and you moved all that money to a new savings account at the same bank? So now you had a checking account with a maximum value of $5,100 and a savings account with a maximum value of $5,100. According to the latest BSA Electronic Filing Requirements For Report of Foreign Bank and Financial Accounts (FinCEN Form 114) - Instructions page 10 : “If the maximum account value of a single account or aggregate of the maximum account values of multiple accounts exceeds $10,000, an FBAR must be filed.” So in the above scenario it would seem that the aggregate of the maximum values of the two accounts is $10,200 and an FBAR must be filed, even though the total amount in that bank is never more than $5,100. I’m still confused and perplexed as to the correct interpretation of the IRS rules which seem ambiguous!
