The term "highest aggregate balance" as used in this IRM, is calculated as follows:
Determine the high balance in each foreign account (to which the violations relate) during each year under examination,
For each year, calculate the "combined high balance" by adding together the high balance of each account as determined in subparagraph (a), and then subtracting any transfers among the accounts during that year as necessary to avoid counting the same funds more than once in determining the "highest aggregate balance" . For example, if Account A’s high balance occurs July 15, transfers into Account A after July 15 are not subtracted; however, transfers into Account B from Account A after July 15 and before the date of Account B’s high balance are subtracted, and
The highest combined balance calculated under subparagraph (b) among all of the years at issue is the "highest aggregate balance" .
The FBAR is required for each calendar year during which the aggregate amount(s) in the foreign account(s) exceeded $10,000, valued in U.S. dollars, at any time during that calendar year. To determine the account value to report on the FBAR follow these steps:
Determine the maximum value in locally denominated currency. The maximum value of an account is the largest amount of currency and non-monetary assets that appear on any quarterly or more frequent account statement issued for the applicable year.
Example: If the statement closing balance is $9,000 but at any time during the year a balance of $15,000 appears on a statement, the maximum value reportable on an FBAR is $15,000.
Note: If periodic account statements are not issued, the maximum account asset value is the largest amount of currency and non-monetary assets in the account at any time during the year.
Convert the maximum value into U.S. dollars by using the official exchange rate in effect at the end of the year at issue for converting the foreign currency into U.S. dollars. The official Treasury Reporting Rates of Exchange for recent years are posted on the FBAR home page of the IRS web site at www.irs.gov. Search for keyword "FBAR" to find the FBAR home page. Current and recent quarterly rates are also posted on the Bureau of the Fiscal Service website at www.fiscal.treasury.gov.
If the filer has more than one account to report on the FBAR, each account is valued separately in accordance with the previous paragraphs.
If a person has one or more but fewer than 25 reportable accounts and is unable to determine whether the maximum value of these accounts exceeded $10,000 at any time during the calendar year, the FBAR instructions state that the person is to complete the applicable parts of the FBAR for each of these accounts and check the "amount unknown" box in Item 15a.
For purposes of determining the violation date balance for accounts where a currency other than U.S. dollars is used, convert the value of the foreign currency into U.S. dollars by using the official Treasury Reporting Rates of Exchange rate. The Treasury exchange rates are published quarterly on March 31st, June 30th, September 30th, and December 31st and are available at https://fiscaldata.treasury.gov/datasets/treasury-reporting-rates-exchange/treasury-reporting-rates-of-exchange. An examiner should use the rate as of the date of the quarterly report for the three months following the date of the report, unless Treasury has issued an amendment to the quarterly report. For example, an examiner should use the Treasury exchange rate published March 31st to convert an April 15th account balance from the foreign currency into U.S. dollars. If Treasury has amended the quarterly report between March 31st and April 15th, an examiner should use the amended rate in effect for the April 15th date.
The information contained in the article is intended only as an educational guide and SHOULD NOT be interpreted as legal advice or taxation advice.
Readers of this information are advised to seek an attorney, certified public accountant(CPA) or enrolled agent(EA) if legal advice or taxation advice is needed. Laws and their interpretation are subject to change at any time. Thus, the accuracy of this information cannot be guaranteed.
Actions taken by readers based on this information are solely at their own risk. Neither the author, Peter Duh, nor the commentators and reactors of Facebook shall have any liability stemming from the information contented in the articles provided.
Disclaimer:
The information contained in the article is intended only as an educational guide and SHOULD NOT be interpreted as legal advice or taxation advice.
Readers of this information are advised to seek an attorney, certified public accountant(CPA) or enrolled agent(EA) if legal advice or taxation advice is needed. Laws and their interpretation are subject to change at any time. Thus, the accuracy of this information cannot be guaranteed.
Actions taken by readers based on this information are solely at their own risk. Neither the author, Peter Duh, nor the commentators and reactors of Facebook shall have any liability stemming from the information contented in the articles provided.