Revolut - travel money app and pre paid debit card

Hi, I use Revolut. It's a smart phone app that comes with a pre-paid debit card. The idea behind it is that you can use it to pay in any currency and they give you the true exchange rate. You pay the funds into a ring fenced Barclay's account. The Barclay's account doesn't belong to the user. You top up your Revolut account with the app. You can hold 3 currencies within the app (USD, EUR, GBP) and exchange amongst them as you please. You can only pay into your Revolut account with a bank account or card in your own name.

I got a notice yesterday saying they've updated their terms and conditions because they are becoming an FCA authorised something or another. When I had a look at the T&C's they had a clause about how you must pay any tax required.

Is there anything to consider being a US expat? I assumed it's just a pre-paid debit card for travel money and there's nothing to do/declare. Since you can "exchange" currencies within the app I wasn't sure if there's something I've missed...

If you need any more info on it just let me know

Thanks

I've not heard of it but it does sound useful.  The only thing I would be sure to do is include it in any FBAR report that is needed.  If you meet FBAR requirements you must report all accounts not just those exceeding $10k. (It sounds like although you don't own the Barclays account you have signature authority in that you can deposit to and withdraw from it)

I've not heard of it but it does sound useful.  The only thing I would be sure to do is include it in any FBAR report that is needed.  If you meet FBAR requirements you must report all accounts not just those exceeding $10k. (It sounds like although you don't own the Barclays account you have signature authority in that you can deposit to and withdraw from it)

Yes it's great, no better way to handle travel money as far as I know

I don't know how I would do FBAR. The Barclay's account is owned by Revolut (I'm assuming) and all payments from all users go into it. I believe it's that way because they weren't a regulated company so they had to keep client's money in a bank for protection. But I have no authority over this account and don't even know the account numbers... I make payments to Revolut through the app with my credit card.

I don't know how I would do FBAR. The Barclay's account is owned by Revolut (I'm assuming) and all payments from all users go into it. I believe it's that way because they weren't a regulated company so they had to keep client's money in a bank for protection. But I have no authority over this account and don't even know the account numbers... I make payments to Revolut through the app with my credit card.

If you don't earn interest or make forex gains there is no tax to be paid and if the Barclays account is wholely owned by Revolut then they are not going to report you to the IRS as an account holder. Do you have an account number with Revolut? It still sounds like it is a "financial institution" since you make deposits to it, hold a balance and then make withdrawals, with them providing the conversion to another currency.

Or, you could forget about it on the very likely assumption that they won't be making reports to the IRS under FACTA, listing you as a USA person with an account. (Have you been asked this by Revolut?)

I read your post as saying that you have a financial interest in a foreign account.  Your account is with the App.  The App provider presumably has a physical address outside of the US which you can use on your FBAR & 8938. The App provider will doubtless be conducting onboarding checks under the laws of whatever jurisdiction it is based in. I'd assume it is reported for FATCA, but that is not your problem.

Is the money safe in case of Barclays or the App provider going bust?

I read your post as saying that you have a financial interest in a foreign account.  Your account is with the App.  The App provider presumably has a physical address outside of the US which you can use on your FBAR & 8938. The App provider will doubtless be conducting onboarding checks under the laws of whatever jurisdiction it is based in. I'd assume it is reported for FATCA, but that is not your problem.

Is the money safe in case of Barclays or the App provider going bust?

ok this is starting to make sense. What information is exactly required to do FBAR? Just highest value of the account and address of the company? I don't have any account numbers or anything as it is a phone app.... This will be the first year I will have to do one. I'm way below the thresholds for 8938

If you don't earn interest or make forex gains there is no tax to be paid and if the Barclays account is wholely owned by Revolut then they are not going to report you to the IRS as an account holder. Do you have an account number with Revolut? It still sounds like it is a "financial institution" since you make deposits to it, hold a balance and then make withdrawals, with them providing the conversion to another currency.

Or, you could forget about it on the very likely assumption that they won't be making reports to the IRS under FACTA, listing you as a USA person with an account. (Have you been asked this by Revolut?)

Forex gains is what I was thinking of.... I don't use it for that purpose, but I always top up in GBP and switch to EUR or USD depending on where I'm buying from. Sometimes I'll put it back to GBP if I've topped up too much. I'm afraid I'll have somehow unknowingly made minuscule "gains". 

Forex gains is what I was thinking of.... I don't use it for that purpose, but I always top up in GBP and switch to EUR or USD depending on where I'm buying from. Sometimes I'll put it back to GBP if I've topped up too much. I'm afraid I'll have somehow unknowingly made minuscule "gains".

I definitely wouldn't consider reporting such small incidental gains or losses of the sort you describe.

As for FBAR, if the total of all your foreign accounts exceeds $10k in any one year then when doing the report list all accounts with names and addresses, and show the highest balance they reached during the year.  If you don't have an account number I wouldn't put one in, or put a made up number if the online form insists on one.  I make up an Employer/Payer Federal Tax ID number every year on my tax return when creating a substitute 1099-R (form 4852) for my UK pension as the software insists on a number in the correct format. (I put 11-1234567).

If FACTA eventually means that UK banks and Pension providers send out US style 1099-R and 1099-INT forms then that will be good. (They have our SSN as we each had to complete an IRS W-9 this year for our bank accounts)