# FBAR question



## frexpat1 (Jan 23, 2020)

I have always reported on my FBAR properly but have a minor issue that has come up.

For 2018, I reported an amount I have an a savings account in account A, all fine.

I manage this account mostly by phone when renewing it, and it always sits there so I don't ever really login to see what it is doing since it is just a savings account with one value. However...

I was filling out the form for 2019 today and finally logged in to the account. I noticed that in 2018 it actually went from account A to B (I think - I am not even totally sure about this), so I should have reported both accounts A and B (even though it was the same amount and I was not aware it had gone from A to B). I assume I shouldn't be concerned about this mistake as the money was actually reported, just with the wrong last digit in the report and not double?

In 2019 it then went from account B to account C at the renewal time. This means that in 2019 to report completely correctly, it's actually account B and account C I need to report, but that would mean that if someone were to dig, they might wonder how it got from account A reported in 2018 to account B in 2019.

My thinking is to report account A (to match 2018's return) and C (to show the transfer during the year), ignoring its stay in account B, even though that is where it actually lived for a while for 2018 and early 2019 that I didn't realise. Having C would show where it is now, and having A would make it match with what was in 2018.

I hope this makes sense? I don't want to get into trouble or get penalties assessed or anything like that, but I had no idea that this money was getting moved at renewal stage to a new account. The only difference is LITERALLY the last digit of the account, and it is the same amount of money. 

Thoughts on how to keep me right on this?

Thanks!


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## Bevdeforges (Nov 16, 2007)

In theory you're supposed to report the "high balance" in each account for the year - so theoretically, it sounds like you should report the same balance in all three accounts for 2019, even though that triple counts the balance.

On the other hand, unless the balance is well into the high 6 figures or more, you may want to simplify your FBAR a bit and just report your "main" account with the balance. Evidently, what the banks report is only the year-end balance (and accounts) and there is little evidence that anyone does any sort of "digging" into what you report other than possibly matching up what the bank reported to what you reported - and that only if there is some question about your tax returns.


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## frexpat1 (Jan 23, 2020)

Bevdeforges said:


> Evidently, what the banks report is only the year-end balance (and accounts)


Is that from the UK too?




Bevdeforges said:


> and there is little evidence that anyone does any sort of "digging" into what you report other than possibly matching up what the bank reported to what you reported - and that only if there is some question about your tax returns.


If I only report the account the money is in now, it'll end in digit C, whereas in last year's it was digit A. Because it is just the bank being stupid and moving it to a new account every time the terms change every year, in theory I am very happy to just submit with digit C at the end. But would it not look odd that without at least A+c reported, that it'll look weird that last year had acct A, and this year only C? Nobody would question the lack of 'overlap' to get the money from one to the other (even if I didnt intend for this myself)?


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## Bevdeforges (Nov 16, 2007)

frexpat1 said:


> Is that from the UK too?


The bilateral agreements regarding FATCA are available online. If you read through them you'll see that they are only required to report the year-end balance on accounts held by "US persons" or those with "US indicia."

There are only a couple of formats for these agreements, and even those vary only slightly in the requirements. The main differences from one country to the next are the lists of types of accounts the banks are NOT required to report.



> If I only report the account the money is in now, it'll end in digit C, whereas in last year's it was digit A. Because it is just the bank being stupid and moving it to a new account every time the terms change every year, in theory I am very happy to just submit with digit C at the end. But would it not look odd that without at least A+c reported, that it'll look weird that last year had acct A, and this year only C? Nobody would question the lack of 'overlap' to get the money from one to the other (even if I didnt intend for this myself)?


No one is going to compare what you filed this year against what you filed last year unless they find something "funny" on your income tax filings. Or if the balances in your accounts run into the millions or something like that. Most issues with FBAR filings come up due to tax audits.


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## frexpat1 (Jan 23, 2020)

So you would just change the last digit, and submit as is, one account?

My bank is not aware I am American so they don't do FACTA submissions for me. So they wouldn't be aware of anything other than if they looked at the last digit last year, then the one this year.


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## Bevdeforges (Nov 16, 2007)

If you're certain they aren't reporting anything for you, I really wouldn't worry about it - maybe even to the extent of just not bothering to file an FBAR at all if it's your own foreign account. But, if you have any potential "US indicia" there is nothing to say that they aren't reporting you "just in case."

You plays the game and you takes your chances.


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## frexpat1 (Jan 23, 2020)

Bevdeforges said:


> If you're certain they aren't reporting anything for you, I really wouldn't worry about it - maybe even to the extent of just not bothering to file an FBAR at all if it's your own foreign account. But, if you have any potential "US indicia" there is nothing to say that they aren't reporting you "just in case."
> 
> You plays the game and you takes your chances.


Since I have filed every year up until now, surely it would be dodgy to suddenly stop? I am happy to continue and keep on the right side of it all as much as possible.

I'd still be nervous about changing a digit and just hoping nobody notices, but argh. I don't want to be slapped with a huge fine over something I had little control over. The money is still being reported.

This whole thing gets people worried and it is just so pointless.


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## Nononymous (Jul 12, 2011)

Point 1 - nobody looks at these things, nobody will notice, nobody cares.

Point 2 - fines can't be collected outside the US anyway.


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