FBAR and de minimis accounts

If you are on the hook for an FBAR filing, say you have an account in the UK with £20,000 or so, are you then required to report each and every foreign account as well?  For example a hypothetical,

Bank A (UK) - £20,000
Bank B (UK) - £52.19
Bank C (France) - 100 euros
Bank D (Germany) - 25 euros

I read if you have two accounts that had say $5,001 each, your aggregate would be $10,002 so you would have to report the accounts, so I'm kind of guessing you have to report all these little accounts once all (or even one) hits the threshold, but wanted to hear what others though.

Yes, in the above example, you would report all 4 accounts on the FBAR.

I was told by staff on the FBAR helpline that the FBAR should even include accounts with a zero balance.

.....and it gets even worse because you should include things that you might not even consider as accounts. Things like the petty cash that you control for a volunteer group you work with and your Oyster card.

.....and it gets even worse because you should include things that you might not even consider as accounts. Things like the petty cash that you control for a volunteer group you work with and your Oyster card.

I phoned the FBAR helpline a while back and asked about Oyster cards and was told that if it is not an account with a financial institution you don't have to report it.

could you tell me what number you phoned for FBAR. I tried w while ago and got transferred to about 6 different offices. I also emailed and they never replied so it would be good to have a contact number.

From http://www.irs.gov/businesses/small/article/0,,id=210244,00.html:

Q. Is there a help line for questions about completing the form?

A. Help in completing Form TD F 90-22.1 (PDF) is available Monday - Friday, 8 a.m. to 4:30 p.m. Eastern time, at 866-270-0733 (toll-free inside the U.S.) or 313-234-6146 (not toll-free, for callers outside the U.S.).

Q. Does the IRS have an email address to send questions regarding the FBAR?

A. You can send questions concerning the FBAR to FBARquestions@irs.gov. The email system does not accept actual FBAR reports.

.....and it gets even worse because you should include things that you might not even consider as accounts. Things like the petty cash that you control for a volunteer group you work with and your Oyster card.

Why do you think this? The instructions clearly state this is about reporting accounts held with financial institutions.  Since when is London Underground a financial institution?  Or since when is petty cash an account?

Why do you think this? The instructions clearly state this is about reporting accounts held with financial institutions.  Since when is London Underground a financial institution?  Or since when is petty cash an account?

That's good to know, but how is the tax payer supposed to know what the Treasury considers to be a financial institution when they encounter language like this?

A financial account includes, but is not limited to, a securities, brokerage, savings, demand, checking, deposit, time deposit, or other account maintained with a financial institution (or other person performing the services of a financial institution).

For the Oyster card, is London Transport "performing the services of a financial institution" by holding your money for you to use in future? Sure, common sense says that's a load of hooey, but is it worth leaving it off the FBAR when omissions have penalties, but the inclusion of stupid CYA accounts doesn't.

Do what you think is right for you, but personally I don't believe that reading ever more into the FBAR regulations is accomplishing anything.

"Awfulizing' a situation is non-productive.

Thanks for the replies to my original question.  If I may go slightly off topic, how do you handle an account that has multiple 'balances'?  For example, I have one account with only one account number.  But the bank lets me keep some of that in USD$, some in GBP£, some in Euros, etc.  It also has a 'savings' and a 'current' setup, but again it's all tied to the same account number (i.e. my one account). 

Do I report each individual balance, like savings balances, checking balance, Euro balance, etc. or do I just report the one overall account when the overall total of all balances was highest?

Thanks for the replies to my original question.  If I may go slightly off topic, how do you handle an account that has multiple 'balances'?  For example, I have one account with only one account number.  But the bank lets me keep some of that in USD$, some in GBP£, some in Euros, etc.  It also has a 'savings' and a 'current' setup, but again it's all tied to the same account number (i.e. my one account). 

Do I report each individual balance, like savings balances, checking balance, Euro balance, etc. or do I just report the one overall account when the overall total of all balances was highest?

This is not addressed in the FBAR instructions but you might find the calculations easiest if you report the "sub-accounts" individually.

Sara, guya has repeatedly claimed that Oyster cards, Tesco clubcard accounts, Nectar points and the like are fair game for FBAR.

Club Card accounts?  It isn't even the same thing as an Oyster Card.  At least with that you can put money in!


I guess you could be like getting someone to buy your groceries or something, but that would be true whether or not you have a clubcard. 

 

Not attacking you DrSuper, just you know, whatever.

I never said it made sense, and I personally think it's daft, but guya has stated this in various threads.