FinCen Form 114 - QQ re the Highest Daily Balance

[yasserak]

Hi

I have an International Current Account outside the US. For Form “FinCen Form 114” I need to report the highest balance during 2021 

Balance was 1000 on 2/1. I added 5000 then withdraw 5500 on the same day on 2/2. So the closing balance for 2/2 is now 500

Should I report 1000 as the max balance or should I report 6000 despite the fact that closing balance on 2/2 is 500 as the money added and withdrawn from the account on the same day?

Thank you

[DoninGA]

You are below the threshold reporting requirements for a FinCEN 114 - https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements

Aggregate value of financial accounts exceeds $10,000 at any time during the calendar year. This is a cumulative balance, meaning if you have 2 accounts with a combined account balance greater than $10,000 at any one time, both accounts would have to be reported.

[yasserak]

Thanks @DoninGA  for your reply

Numbers I gave is just an example... the total aggregate accounts is more than the threshold so I have to report the FinCEN 114.... So my question is how to determine the max balance? should I stay with the daily closing balance in each day to determine the balance or should I consider the credit and debit transactions each day as well?

Thank you

[DoninGA]

At any time during the tax year where the balance of all foreign accounts exceeds $10,000 then you must report on the BSA E-Filing System.

Go to this website for support - https://bsaefiling.fincen.treas.gov/Help.html

[yasserak]

Thanks for your reply, Yes, I will use the BSA E-Filing System, Let me try to clarify my question with another example 

Balance was 11K on 3/1. I added 5K then withdraw 9K on the same day on 3/2. So the closing balance for 3/2 is now 7K 

Should I report 11K as the highest balance on 3/1 (since the closing balance on 3/2 is 7K) ... Or should I report 16K (which is 11K + 5K) as the max balance despite the fact that closing balance is still 7K on that day?

Thank you

[DoninGA]

That is a question you should be asking the support folks for the BSA system.  I do not have that particular information readily available to give you a firm answer.

[yasserak]

Ok, thank you!