# Fbar Account Type



## albator73

Hi,

Hope I didn't skip this post, but I been reading a lots on this forums and I'm still not sure which account I need to declared for the FBAR.

In Quebec (Canada), our bank, Caisse Populaire Desjardins, when you open an account give you automatically a Check, Saving, RRSP and Social account (need to put $5 in this account and leave it there, don't ask). Plus they offer a line of Credit and Credit Card. Since I have 2 accounts (personal and couple), I have to double everything.

Do we have to report and what is the type for the following account:
- Line of Credit?
- Credit Card?
- Social account?
- TFSA (Tax Free Saving Account)?

Do we have to report $0 account?

Thanks
Albator73


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## Bevdeforges

What I have done in the past (and gotten away with) is to report these "multiple" accounts all together. If there is a "main" account that groups the checking, savings and whatever other accounts, report that account number and then for the maximum balance, just combine the balances. The theory is that by knowing the "main" account information they have access to the whole account.

In your case, I'd report one account for your personal group of accounts and one for the couple group of accounts. As long as they are in the same bank and reported together, that should suffice.
Cheers,
Bev


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## albator73

Merci Bev and all other. 

Yeah! In 3 month of going over fear, sleepiness, nightmare, try understanding, searching info and finally requesting all bank account archive and compiling data. I finally send all my FBAR. What a relief. 

I finally left all accounts since everything was already enter except for line of credit and credit card. It was more easy I tough, after you made you spreadsheet with all the numbers. I use the IRS average annual currency to convert In US. 

Only place I'm still not sure is about what type TFSA ( Tax free saving account) is. I play safe since it is not tax and enter "bank" instead of "security" or other. 

I had a small letter of explanation and mail all 6 year together. Et voila!
FBAR CHECK!

Albator73


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## Bevdeforges

Congratulations! Despite the "shock and awe" campaign they seem to have conducted in Canada on the subject, for the FBAR forms at least it seems what they actually are looking for is a good faith "best effort" and nothing more. I once had them come back to me with a question on the FBAR form I had filed - I answered it and that was the end of it. So, well done!
Cheers,
Bev


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## UStoCA

Bevdeforges said:


> Congratulations! Despite the "shock and awe" campaign they seem to have conducted in Canada on the subject, for the FBAR forms at least it seems what they actually are looking for is a good faith "best effort" and nothing more. I once had them come back to me with a question on the FBAR form I had filed - I answered it and that was the end of it. So, well done!
> Cheers,
> Bev



Bev, you're certainly a great wealth of information and I certainly thank you for that.


Do you know if you need to file mortgage accounts on the FBAR as well?
What about standard credit cards (ie not pre-paid)?


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## Bevdeforges

UStoCA said:


> Bev, you're certainly a great wealth of information and I certainly thank you for that.
> 
> 
> Do you know if you need to file mortgage accounts on the FBAR as well?
> What about standard credit cards (ie not pre-paid)?


AFAIK you don't include mortgages nor credit cards on the FBAR (at least I don't). FBAR are for financial accounts. I believe it's the FATCA forms which, if you're required to file them, want all your financial contracts as well as bank and investment accounts.
Cheers,
Bev


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## UStoCA

Bevdeforges said:


> AFAIK you don't include mortgages nor credit cards on the FBAR (at least I don't). FBAR are for financial accounts. I believe it's the FATCA forms which, if you're required to file them, want all your financial contracts as well as bank and investment accounts.
> Cheers,
> Bev



Bev, I appreciate the insight as always.

It looks like FACTA is also concerned with financial accounts (which have a positive value so loans would be excluded) rather than hard assets (house, cars, etc).

Is this assessment correct or am I missing something?


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## Bevdeforges

The FATCA stuff is all fairly new - and I stopped reading as soon as I saw the $200,000 threshold. (No way I exceed that.)

But this page from the IRS should give you everything you need to know: Foreign Account Tax Compliance Act (FATCA)
Cheers,
Bev


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## Mona Lisa76

I have been cautious and reported virtually anything that could be arguably a financial account including my travel card, paypal, alertpay, pre-paid telephone sims, and even my credit card because I have sometimes overpaid it and thus sometimes had a positive cash balance on it. Plus, of course, the more obvious types of accounts such as saving, checking, investment brokerage account, pension plan, etc. Better to over-report when in doubt.


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## UStoCA

Are people really having to report their Paypal accounts too? I wouldn't have thought of that in a million years. 

Too bad someone can't make up a master checklist of accounts for the FBAR reporting requirements.

Anyway I spoke to my accountant in the US and was told that mortgages, credit cards and other items which remain negative at all times throughout the year do not need to be reported on the FBAR (if you overpaid them, then perhaps you should be reporting). However, mortgage accounts that support the transfer of funds (such as what Caisse Populaire issues attached to a mortgage.....checking, savings, social acct, etc) do need to be reported since they often have a temporary positive balance. I think on a mortgage account using Bev's method of conglomerating all your positive accounts and summing the balance will work fine since later when the banks are forced to report in 2014 they will likely only be asking for the year ending balance on any accounts (and probably only ones with over $50,000 in assets). If you do carry large balances on any accounts (over $50k), it may be better to break that out individually. It was also suggested by my US accountant that in the past if you had forgotten to add an account, that you should just begin adding it right away to your FBAR forms when you next file (essentially follow an "in compliance from this date forward" principle). Then worst case if you are formally audited, the examiner can't argue that the account was hidden or not disclosed.

I don't have any experience to amending the FBAR going backward (or if there is even a need) so if anyone has any experience (penalties? letters?) or advice (contrary to what was given to me) on that I would be all ears.

Luckily I fall short of FACTA at this point, but hopefully they don't begin lowering the limits later.


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## Bevdeforges

I agree with your accountant. Report enough to show you're not hiding anything, but report in gross wherever you can. 

Frankly, unless you have large or complex financial holdings, the IRS is mainly going to be concerned with the current balances being reported by the foreign banks and financial institutions - not with combing prior years' balances for minor and unintentional errors. Then there is the question of just what the banks are going to be reporting come 2014 or whenever they are supposed to report on US persons' accounts.
Cheers,
Bev


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## Mona Lisa76

UStoCA, I feel it's safer to err on caution and over-report because all it is a nuisance more than anything else. After all, I have had positive balances on both my credit card balance and paypal so felt it was safest to go ahead and report it on both the Fbar and 8938.


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## UStoCA

Mona Lisa76 said:


> UStoCA, I feel it's safer to err on caution and over-report because all it is a nuisance more than anything else. After all, I have had positive balances on both my credit card balance and paypal so felt it was safest to go ahead and report it on both the Fbar and 8938.



I don't disagree at all, I was just surprised because I hadn't even thought of a Paypal account.......just shows how easy it is to have a simple/innocent oversight when trying to report all your accounts.

Requirements for form 8938 outside the US (you must be over one of those limits to need the form):
You are required to do the filing of 8938 if the total value of your specified foreign financial assets is more than $200,000 on the last day of the year or more than $300,000 at any time during the year.

Luckily it only covers financial assets and not physical assets like cars, houses, boats, jewelry, coins, etc.....what a PITA that would be.


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## Mona Lisa76

I'm of the opinion that if one makes a good faith effort to comply, or as in my case correct past mistakes, that the IRS and DOJ will be understanding (though I still wound up owing a five figure sum in double taxation to the US). I was very upset, naturally, but accept that I should have taken my US citizenship into account when doing my fibancial planning from the UK.
However, I'm an anomaly as most expats will not owe any taxes.

In my view, though the IRS would prefer expats with compliance issues to enter into OVDI so they can get 27.5% misc FBAR penalties on foreign account balances, they still appear to be accepting quiet disclosures and delinquent fbars with reasonable cause letters though you still need to seek a professional opinion. Good luck!

I was over the threshold so had to file 8938 too.


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## UStoCA

Mona Lisa76 said:


> I'm of the opinion that if one makes a good faith effort to comply, or as in my case correct past mistakes, that the IRS and DOJ will be understanding (though I still wound up owing a five figure sum in double taxation to the US). I was very upset, naturally, but accept that I should have taken my US citizenship into account when doing my fibancial planning from the UK. However, I'm an anomaly as most expats will not owe any taxes.
> 
> In my view, though the IRS would prefer expats with compliance issues to enter into OVDI so they can get 27.5% misc FBAR penalties on foreign account balances, they still appear to be accepting quiet disclosures and delinquent fbars with reasonable cause letters though you still need to seek a professional opinion. Good luck!
> 
> I was over the threshold so had to file 8938 too.



Mona Lisa, I'm terribly sorry to hear you got caught up in all this nonsense going on, but I agree you probably had more than enough foreign assets where legal counsel and an accountant should be a mandatory first step. If you decided not to go into the OVDI, personally I think you made the right choice since I believe it is a government scam set up more to ensnare residents in the US than those abroad, but I'm no lawyer and it's important to always weigh all your options. 

In my case I was very lucky that my only significant asset (other than just general wages) was an investment account in the US (so no FBAR) which I did not have until after I immigrated to Canada (otherwise the US could claim the account for taxation). Under this premise, the tax treaty applied and all my taxable gains were owed to Canada since the gains rates here are higher than in the US (on long term gains anyway........Canada makes no distinction between long or short tem gains). I then had to turn around and file foreign tax credits on my US return which brought my taxes to nothing. Had I owned a pension, investment account or RRSP (like 401k) in Canada, my situation could have been quite different. I agree with you, bottom line is that if you have money worth investing, you should be spending money on top notch tax planning advice as well.

I think the biggest issue right now is that even people with very limited assets who may have omitted accounts with tiny balances fear massive penalties for the FBAR. This is where I think the program spawns massive badwill across the globe and it remains to be seen how other countries will push back on the 2014requirements.


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## UStoCA

I emailed my accountant about including Paypal on your FBAR and his comment was that it is a US company (owned by eBay and therefore no FBAR) that is simply holding your money in a foreign currency and uses foreign bank accounts (which are reportable) to transmit or recieve any funds. Looking online it appears that some experts (both lawyers and accountants) are giving advice on both sides about whether to report it or not. My big concern with Paypal is that your account number is your email address (unless I'm mistaken) and I absolutely don't trust the government to have my email address under any circumstances (not that there's anything to hide, but that smacks of communist type privacy invasion IMHO). 

It will be very interesting in the coming months and years to see how this all plays out but I'll bet money when the foreign banks start feeling the IRS pain to report like we are, the foreign diplomatic pressure will be enormous to reverse or at least seriously neuter the current FBAR and FACTA regulations passed by congress. So until then, keep burying them in paper.


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## UStoCA

Just to add to what I said above, here's the definition of a financial account from the IRS:



> A financial account includes a:
> 
> Bank account, such as a savings, demand, checking, deposit, time deposit, or any other account maintained with a financial institution or other person engaged in the business of a financial institution. A bank account set up to secure a credit card account is an example of a financial account. An insurance policy having a cash surrender value is an example of a financial account.
> 
> Securities, securities derivatives, or other financial instruments account.
> 
> Other financial accounts generally encompass any accounts in which the assets are held in a commingled fund and the account owner holds an equity interest in the fund. A mutual fund account is an example of such an account.
> 
> Individual bonds, notes, or stock certificates held by the filer are not a financial account.



Clearly they have excluded such accounts as credit cards, but have included supporting accounts. I believe Paypal also falls outside the definition at this point, but again I would suppose if you were selling items (ie making money) or recieving money and transferring it back into other accounts (especially if you should be paying taxes on the money), it would be worth reporting. I think Paypal will be also be required to provide 1099k forms to people for income reporting at some point too but not sure when that comes into effect.


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## Bevdeforges

UStoCA said:


> It will be very interesting in the coming months and years to see how this all plays out but I'll bet money when the foreign banks start feeling the IRS pain to report like we are, the foreign diplomatic pressure will be enormous to reverse or at least seriously neuter the current FBAR and FACTA regulations passed by congress. So until then, keep burying them in paper.


There is also the question of exactly how much "pressure" the IRS can (or will) apply to foreign banks and other financial institutions in 2014. The banks that are dumping US customers and refusing to open new accounts for US persons are mostly those in Germany and Switzerland. The Germans are well known for following rules no matter how stupid they may be, and the Swiss have been the targets of the US (and other countries') money laundering and "offshore" account investigations for years because of the notoriety of secret Swiss accounts.

I recently met with my bank here in France and they hadn't heard a word about all this, didn't really care when I "declined to reply" when asked if I had retained my US nationality when I took French citizenship (they just wanted my French i.d. card number for their files) and frankly if the IRS ever looked twice at my bank, I'd be amazed. I get the feeling the French banks answer "to a higher power" (namely the Banque de France).
Cheers,
Bev


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## CDN Roots

*FBAR Reception – How To Verify?*

Hi ... 

Sorry if this was already mentioned elsewhere, I was looking and couldn't find it ... 

Is there a simple way to confirm that one's FBAR filing has actually been received once it is sent off?

I've managed to get my 1040 reporting up to date and confirmed reception however those same individuals cannot comment on if the FBAR reports made it – different department.

I've found US-only toll free numbers that don't work from Canada, and nothing else.

Maybe there's a phone number? An email address? 

Just wondering. Maybe 'no news is good news' ... but negative confirmation isn't always the best strategy with important documents.

Thanks for any info!

CR


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## UStoCA

CDN Roots said:


> Hi ...
> 
> Sorry if this was already mentioned elsewhere, I was looking and couldn't find it ...
> 
> Is there a simple way to confirm that one's FBAR filing has actually been received once it is sent off?
> 
> I've managed to get my 1040 reporting up to date and confirmed reception however those same individuals cannot comment on if the FBAR reports made it – different department.
> 
> I've found US-only toll free numbers that don't work from Canada, and nothing else.
> 
> Maybe there's a phone number? An email address?
> 
> Just wondering. Maybe 'no news is good news' ... but negative confirmation isn't always the best strategy with important documents.
> 
> Thanks for any info!
> 
> CR



I've just been sending mine registered mail or at least with a tracking number so I have proof it was recieved.

It costs a bit more but I've never had any issues thus far using that strategy.


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## UStoCA

UStoCA said:


> I emailed my accountant about including Paypal on your FBAR and his comment was that it is a US company (owned by eBay and therefore no FBAR) that is simply holding your money in a foreign currency and uses foreign bank accounts (which are reportable) to transmit or recieve any funds. Looking online it appears that some experts (both lawyers and accountants) are giving advice on both sides about whether to report it or not. My big concern with Paypal is that your account number is your email address (unless I'm mistaken) and I absolutely don't trust the government to have my email address under any circumstances (not that there's anything to hide, but that smacks of communist type privacy invasion IMHO).



I thought I would update this again since my accountant came back later and said after talking with some colleagues they are now recommending to include your foreign Paypal accounts on the FBAR too. Thought this might be helpful since finding useful information on the subject is quite difficult.


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## Mona Lisa76

UStoCA said:


> I thought I would update this again since my accountant came back later and said after talking with some colleagues they are now recommending to include your foreign Paypal accounts on the FBAR too. Thought this might be helpful since finding useful information on the subject is quite difficult.


Mine also agrees; in fact any foreign account with a potentially positive cash balance should be included, including travel cards, store bonus cards, pre-paid phone cards, overpaid credit cards, etc. It's why I counted over 43 accounts and thus filed the shortened form whereby I just list the. number of accounts and sign!

I consequently wouldn't be surprized if they contact me with questions about what exactly I have...it's been a full year but they still have another five years to investigate, as there's a six year statute of limitations...but as I will also have to fully disclose everything on my 8938 form directly attached to my 1040, doubt they will audit me. Still, though, I believe it's safer to fully disclose, given how draconian they're becoming.


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## UStoCA

Mona Lisa76 said:


> Mine also agrees; in fact any foreign account with a potentially positive cash balance should be included, including travel cards, store bonus cards, pre-paid phone cards, overpaid credit cards, etc. It's why I counted over 43 accounts and thus filed the shortened form whereby I just list the. number of accounts and sign!
> 
> I consequently wouldn't be surprized if they contact me with questions about what exactly I have...it's been a full year but they still have another five years to investigate, as there's a six year statute of limitations...but as I will also have to fully disclose everything on my 8938 form directly attached to my 1040, doubt they will audit me. Still, though, I believe it's safer to fully disclose, given how draconian they're becoming.




If I started to include credit cards and store cards too, then I'd be filing the short list for sure. Makes me wonder if the best strategy isn't to just make sure you have more than 25 accounts so you can automatically file the short form each year. Still wouldn't eliminate the the need to keep detailed records though.


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## byline

CDN Roots said:


> Hi ...
> Is there a simple way to confirm that one's FBAR filing has actually been received once it is sent off?


The only way I know of is to call. I sent mine registered mail, but no one ever signed for it, so the last entry I see in in the post office tracking info is that it has entered a foreign country. Sorta defeats the purpose of sending it registered mail, eh?

Anyway, I called and got one of the more annoying phone agents who sounded indignant that I had bothered to call at all. After yammering on and on about how they might or might not have it, they get thousands of pieces of mail every day, yadda, yadda, yadda, she finally seemed to locate it on her computer ... only to tell me that I'd filled out the wrong form (the 2008 version), so they'd be sending me instructions on filling out the correct one. I told her no, I was pretty sure that I'd been careful to fill out the most current form posted on the IRS website, and she exclaimed, "I'm looking at it right now!" OK. I didn't have it right in front of me, so I didn't argue with her.

But then I got out my copy of the form, and sure enough it says it was revised January 2012. So I decided to call back, hoping I'd get a different agent. Thank heavens, I did. I started all over again. She was much more polite and efficient, just looked up my form and said it had been received and processed. Thank you, that's all I needed to know. *sigh*


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## wvza

*Really Need Some Help*

Here goes, i will try to include as much information as I can.

1 1/2 years ago my wife and I found out about the us tax thing. She is US citizen and I am canadian. We married 20 years ago and she has lived here ever since. She filed her us tax the first year here but has never filed since. We have lived in canada for the past 20 years.

My wife has no RRSP's, stocks. bonds etc.... However, we do own a business we bought in 2005. It is a registered incorporated company She is 100% owner of all shares as I had some financial problems at the time and could not have my name on the business ownership.

We each earn around 75k a year from the company. All taxes are paid and we are both in good standing with all Canadian tax laws personally and corporately. 

When we first heard about this my wife and I panicked a bit and she joined the OVDI program. Not sure that was the right thing to do.... We got a letter several months after that saying to send everything in. However, our accountant said it would not be a bad idea to wait a while and see how things played out.

We have been waiting and today just received a letter in the mail stating that we have 30 days to file everything or criminal prosecution may start against my wife.

These are my questions

1) Can we opt out of the OVDI and go with a quiet disclosure or is it to late? I don't think the OVDI is the right course for us after reading more on it.

2) Will our business account be penalized under the fbar? My wife and I both have signing authority on it. The account at times have a balance of up to $300-400k. Can they penalize this even if it working capital and not business profit?

3) My wife's name is on our house. Have about 100k of equity in the house. Should I take her name off the house?

4) We have no accounts that have more than 10k in them. Do we still have to file the fbar? The only account that goes about 10k is the business account

5) Can my wife denounce citizenship before all the tax issues are resolved or must that be done first?

Any help would be greatly appreciated. I have not yet told my wife about the letter we received today as I am hoping that I can gather some further information before telling her. I know she will be highly stressed about it. I would like to wait until after Christmas and then deal with this but am not sure if that is a good thing to do.

Anyways, hope someone out there can help me or point me in the right direction.


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## Bevdeforges

OK, I agree, filing for the OVDI program was probably not a great idea. You may want to try contacting the IRS to see if you can opt out because you don't really seem to fit the profile.

On the business account - if your wife is a signer on the account, she should be reporting it on an FBAR filing - in the appropriate section (i.e. she has signature authority, but no financial interest - yeah, I know it sounds weird, but that's the appropriate category for a business account like this).

On the business, as long as she is working in the business, she shouldn't have to declare it, nor fill out any of those other forms about it. There is a clear exemption for shares in a business that is your livelihood. I.e. you are required to report only shares and ownership interest in a foreign corporation held for investment purposes. As long as she is reporting her salary from the business and her signature authority in the accounts, she's disclosing what needs to be disclosed.

The FBAR filing is required when the TOTAL of the accounts she owns or has a signature authority over is above $10,000. She should report them all - though when reporting the business account, she only has to disclose the name and address of the company, not the account details (like the bank and account number). 

If your wife chooses to renounce her citizenship, they will check to see that her past filings are up to date, and her tax obligation ends only after the date that the renunciation comes through and that can take a while.
Cheers,
Bev


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## UStoCA

wvza said:


> These are my questions
> 
> 1) Can we opt out of the OVDI and go with a quiet disclosure or is it to late? I don't think the OVDI is the right course for us after reading more on it.
> 
> 2) Will our business account be penalized under the fbar? My wife and I both have signing authority on it. The account at times have a balance of up to $300-400k. Can they penalize this even if it working capital and not business profit?
> 
> 3) My wife's name is on our house. Have about 100k of equity in the house. Should I take her name off the house?
> 
> 4) We have no accounts that have more than 10k in them. Do we still have to file the fbar? The only account that goes about 10k is the business account
> 
> 5) Can my wife denounce citizenship before all the tax issues are resolved or must that be done first?
> 
> Anyways, hope someone out there can help me or point me in the right direction.



Bev had some great advice and hopefully I can help a bit as well.

1) I would contact an accountant on this that specializes in Expat taxes to get their advice on how to handle it. I agree it was not the greatest idea to enter it in the first place (the IRS always uses fear as their greatest weapon so keep this in mind when dealing with them) but now you need to do a little stick handling to make sure you get the best possible solution to your situation. Even if you need to pay for the advice I would do so. I've had great luck with Greenback Expat Tax Services but there are certainly others out there who are knowledgeable in this area too.

2) I suggest you familiarize yourself with the following link, lots of good info in there:

Internal Revenue Manual - 4.26.16 Report of Foreign Bank and Financial Accounts (FBAR)

I haven't seen this exemption Bev was talking about, but again I would definitely speak with an accountant specializing in US Expat taxes for advice on which accounts do or don't need to be filed.

3) No need to panick here but if you are concerned about the IRS coming after assets, I would take her off the house. They can't touch property of non-US citizens in Canada.

4) The need to file FBAR is based on the aggregate of accounts so if at any time you had more than $10k combined in your accounts, you need to file FBARs on all of them. One suggestion here is to aggregate your accounts (ie if you have a savings, checking, credit card, etc all under one account, add it all together and file it under one account number on your FBAR).

5) This is a big no. The US has you 6 ways from Sunday on that topic and has done alot to make sure people are completely blocked from renouncing for tax purposes. You can't run from this so your best option is to arm yourself with the best advice you can get and work through the issue. Again fear is your worst enemy here and the IRS has millions of people filing taxes to sort through each year. It is always best IMHO to be proactive and at least have the appearance you were looking to cover your obligations in good faith.


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## Bevdeforges

Take a look at this page on the IRS website: http://www.irs.gov/Businesses/Corporations/Foreign-Account-Tax-Compliance-Act-(FATCA)

There are numerous documents referenced that define and discuss just what it is that they are looking for in these FATCA declarations and filings. In several place they define a "specified financial asset" as stock held for investment purposes. I would argue that if you own stock in a small business run by you and other family members and where you work, that you do not own that stock for "investment purposes." There are also references to assets "used in a trade or business" and other definitions that may give someone a better idea of a basis on which they could justify not reporting their ownership interest in a small, family business. 

Like all tax documents, it's not light reading, but as long as you can justify your position - and demonstrate by what you do file that you aren't hiding anything from them that would fatten an auditor's "recovery rate" if they audited you, then they aren't going to waste much time reviewing your file.
Cheers,
Bev


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## Pacifica

Hi WVZA,

Re (1), you can opt of OVDI at any time before you sign the closing agreement. If you opt out, it doesn’t morph into a Quiet Disclosure (it's already noisy)-- but outside OVDI the IRS agent has much more discretion than within OVDI, and can take “reasonable cause” into consideration for not filing on time. From the few opt-out cases I know of, they do seem to be rather reasonable with minnows-outside-the-US who opt out if they’re bona fide and can show they had reasonable cause (It's not a big sample, but I know of a few minnows-outside-the-US who opted out and got FBAR penalties waived.) 

You might want to check out Jack Townsend’s Blog as a lot of people have written about their OVDI experiences there. Don’t let the name of his blog, Federal Tax Crimes, spook you – most articles there don’t have anything to do people like us -- but there are also about a dozen or so very good articles/threads on OVDI (and OVDI Opt-Out) for minnows. Here’s a link to an article there that a minnow wrote describing his opt-out experience. To find the other OVDI threads, just go down to the bottom of the sidebar (way down), where the topics are listed alphabetically.

Re (5) renunciation will terminate one’s citizenship effective the date they sign the renunciation oath and no new tax liability will be incurred from that date forward (except on US income, if you have any after that date). You do not have to be tax compliant at the time of renunciation. You have until June 15th or the following year to do that. But you must certify on your exit tax return (due June 15th of the following year) that you have complied with your tax obligations for the past 5 years.


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## Tully123

Hi Bev,
I have been filing Fbar for 4 years and last year did the 8932 as well. This year I am not sure if I need to include a demand loan made to spouse. The money came from an account that was included last year so that account will now have a zero balance. The loan is zero interest until called by me so it doesn't generate income. Is this still considered a financial account. Really don't want to do this wrong and be subject to $10,000 fine!
Thanks, Michael


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## Bevdeforges

Though I obviously don't know all the terms and conditions, I'm tempted to say that "inter-family" loans like this aren't worth reporting. The fact that your account now has a zero balance just means you "spent" the money and won't need to report it in future.

Frankly, on FBARs you really only are reporting accounts, not loans. 
Cheers,
Bev


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