How report maximum value in a foreign bank account, if the same money was in two different accounts at two different times

[dasherson]

I have two foreign accounts to be reported on Form 8938 and FBAR.

Account 1: On May 1, 2019 the maximum value in this account was $150,000.  On May 13, 2019 this $150,000 was transferred to Account 2. The next day, May 14, 2019 the $150,000 was wired from Account 2 to me in the USA.

Do I need to report the maximum balance in Account 1 as $150,000, AND ALSO report the maximum balance in Account 2 as $150,000?  

[KurtL1 · Accepted solution]

Yes, you need to report both accounts. Even though the funds only remained in Account 2 for a short time. the requirements do not specify the length of time required for the funds to be in the account.

Per IRS FBAR Reference Guide A United States person must file an FBAR if that person has a financial interest in or signature authority over any financial account(s) outside of the United States and the aggregate maximum value of the account(s) exceeds $10,000 at any time during the calendar year.

Per Instructions for Form 8938 if the total value of your specified foreign financial assets is more than $100,000 on the last day of the tax year or more than $150,000 at any time during the tax year, if you are married.

If the total value of your specified foreign financial assets is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year, if you are single.

[dasherson]

Thank you for your reply. I do complete a Form 8938. On Part 1 of Form 8938 Point # 2 - 'Maximum Value of all Deposit accounts', I should enter $300,000 and not $150,000? The total amount of money I owned was $150,000.

[KurtL1 · Accepted solution]

You are welcome.

You are correct the Maximum Value on all Accounts should be $300,000.