My foreign account never exceeded $10,000 on its balance, but in total I had roughly $11,000 move through over the course of a year. Do I need to report it?

[Anonymous]

I had a foreign account for 2015 that had monthly balances of less than $10,000. I never had more than a few thousand dollars per month in the account. However, over the course of the year, I had moved about $11,000 through it. Does this mean I am required to report the bank account? It wasn't clear to me through the rules whether the FBAR requirement was $10,000 over time or in regards to the amount of money the account held at any given point. 

Thanks!

[DS30 · Accepted solution]

No, you only need to file an FBAR if all your foreign accounts added together were over $10,000 on any day during the year (not if more than $10,000 was transferred through the accounts over the course of a year).

According to the federal government;

If you have foreign bank accounts, you may be required to file a Report of Foreign Bank and Financial Accounts (FBAR) if are a US citizen or resident and:

1. you had a financial interest in or signature authority over at least one financial account located outside of the United States; and
2. the aggregate value of all foreign financial accounts exceeded $10,000 at any time during the calendar year reported.

To be directed to the US Treasury Government Website to prepare a Report of Foreign Bank and Financial Accounts, click FBAR (TurboTax does not support this form)

[foxy1]

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!