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IRM guidance 4.26.16.1.7 (08-26-2025), for calculating individual accounts’ high balances when filing FBAR

Hello,

I hope the response to my question from the experienced forum members would be useful for others as well and in a similar situation.

I have been regularly filling FBAR for many years. However, I have a new situation that I need to be prepared for.


From my trading account, I sold few stocks and then transferred the funds to the bank account linked (say Account A) to the trading account. Subsequently, I transferred the money over to another account (say account B) under my ownership. Then reinvested the money (adding some funds which was already in already in account A) in a Fixed deposit, which has a unique account number.

 

In all my previous FBAR filings, I have been listing the value of Trading account, account A and account B as separate lines in the FBAR form. I plan to follow the same approach in 2026 as well.

 

My question.

1) Can I use the IRM guidance 4.26.16.1.7 (08-26-2025), when computing the high balances of accounts A and B? So that I don’t double count the funds got from stocks sales which was further transferred between them.

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