Does the sum/aggregate of all accounts (of both the spouses) need to be calculated on any single day to determine if they meet the reporting thresholds? Or is the aggregate to be calculated by adding the maximum value of each account in the year i.e. values from different days?
For example, in the below scenario:
Assuming:
a) Reporting threshold of $150,000 (married filing jointly)
b) Account A belongs to me
c) Account B belongs to my spouse
Account A holds $90,000 on 22nd April 2024.
Account B holds $0 on 22nd April 2024.
Account A holds $0 on 1st May 2024.
Account B holds $70,000 on 1st May 2024.
In the above case is the reporting threshold met for 2024? Thanks.
The IRS says in this IRS document. page 8:
You must report the maximum value during the tax year of each specified foreign financial asset reported on Form 8938.
In your case, account A must be reported at $90,000 and account B must be reported at $70,000. The total is $160,000 which is over the threshold of $150,000, requiring you to file form 8938.
Thanks @MinhT1 for your response.
So based on your response even if the maximums were on different days for different accounts we would aggregate them as such?
Yes, you will aggregate even if the amounts differ on different days. You take the highest balance of each account separately and add those together to determine if the form must be filed.
Then, you file as MinhT1 describes. The IRS is aware that taxpayers will regularly move money around and that this will cause these reports to not be representative of net worth. It's pretty common for folks to move the same funds around, sometimes to several accounts in a year. For example, from checking, to high yield savings, then back with additional interest, etc.