Should dual status aliens file FBAR and FATCA forms if during the year they didn't own foreign business or trust, the balance of foreign accounts never reached $10K, and they had no foreign financial assets at the end of the year?

[JanX]

My spouse and I are dual status aliens (with green card) choosing to be treated as US residents for the entire year and reporting worldwide income.

Should we file FATCA and FBAR forms if during 2023:

• we didn't own any foreign business or trust;
• the aggregate balance of our foreign bank accounts never reached $10,000 and we didn't have a signature authority over any corporate or third-party bank accounts;
• at the end of the year we didn't hold any foreign financial assets except the foreign debit card with a balance of few hundred dollars;

[AmyC]

It sounds like you are not required to file but cryptocurrency has been added as an asset so you may need to re-evaluate. That said, it never hurts to file the form.  If there is any doubt, better to file.