U.S. Expats FBAR for 2019

[ProbPossConf]

The current rate of exchange as of December 31, 2019 has been posted on the Bureau of Fiscal Service website.

The Thailand-Baht rate is 29.7700 shown on the following link:

      https://www.fiscal.treasury.gov/reports-statements/treasury-reporting-rates-exchange/current.html

 

[Jingthing]

Are FBAR filings for 2019 accepted this early or is there a later starting date? 

[lopburi3]

Expect a few not expecting to have to file will be required to do so with that exchange rate.  Thai baht 29.7700

[GregTN]

I don’t think that is the proper rate you use to actually file your FBAR report.  It is  normally posted on the IRS website and I only see 2018 rates at this time.  

[Pib]

26 minutes ago, GregTN said:

I don’t think that is the proper rate you use to actually file your FBAR report.  It is  normally posted on the IRS website and I only see 2018 rates at this time.  

The IRS does not have official exchange rates.  See partial quote below from IRA website.  One US govt website the IRS will refer a person to get an exchange rate is the US Treasury Exchange rate page given earlier.

 

https://www.irs.gov/individuals/international-taxpayers/yearly-average-currency-exchange-rates

 

Quote

 

Currency exchange rates

The Internal Revenue Service has no official exchange rate. Generally, it accepts any posted exchange rate that is used consistently.

 

 

 

 

And for the exchange rate used for the FBAR, below partial quote is from the FBAR completion instructions.  The recommend/prefer the US Treasury rate per webpage given earlier.

 

Quote

Step 2. In the case of non-United States currency, convert the maximum account value for each account into United States dollars. Convert foreign currency by using the Treasury's Financial Management Service rate (select Exchange Rates under Reference & Guidance at www.fms.treas.gov) for the last day of the calendar year. If no Treasury Financial Management Service rate is available, use another verifiable exchange rate and provide the source of that rate. In valuing currency of a country that uses multiple exchange rates, use the rate that would apply if the currency in the account were converted into United States dollars on the last day of the calendar year.

 

 

 

[lopburi3]

As said the OP is the exchange rate used for FBAR (which is not IRS).  For IRS you can use any normal official exchange rate source and for many OANDA or XE seem to be the easy to document if questioned later.

[jeffandgop]

Coincidentally, I filed mine a few hours ago...I used 30B=$1USD as it was CLOSE ENOUGH...been doing this for years and never any objection by Treasury.....

[mogandave]

Yeah, they’s no downside to just rounding up 

[lopburi3]

36 minutes ago, mogandave said:

Yeah, they’s no downside to just rounding up 

Actually you are rounding the total USD down by using a higher baht rate so there could be a downside.  But for normal people likely not much of an issue as law is designed to catch Mafia types when they can not find anything else.

1 Million baht at 29.77 = $33,590.87

1 Million baht at 30.00= $33,333.34

[JimGant]

You can still use last year's FBAR fill-in-the-blanks form, as it is identical to this year's, and still labelled Version 1.0. This year's only change, that I can discern, is they change filing info to this:

"The deadline to file the Report of Foreign Bank and Financial Accounts (FBAR) to FinCEN
coincides with the current IRS tax season filing deadline for annual tax returns." And put an April 2019 date on it. No instructions about "This form supercedes previous forms." So, if most of your account info is the same, just change out the new dollar figures. Makes matters very simple.

 

[JimGant]

On 1/10/2020 at 5:01 PM, jeffandgop said:

Coincidentally, I filed mine a few hours ago...I used 30B=$1USD as it was CLOSE ENOUGH...been doing this for years and never any objection by Treasury.....

And why would there be any objection -- the FX rate for the FBAR doesn't drive any tax figure owed, unlike the FX figure you use for the interest income posted on your Schedule B. Whether you use 29 or 35 baht to the dollar, Treasury still gets a feel for high, medium, or low level foreign account holder -- if they even analyze that in isolation..... (?) The FBAR is just an Al Capone vehicle they use to stick it to tax cheats and money launderers they identify by other means.

[metisdead]

Some off topic posts have been removed. 

[taxout]

"For IRS you can use any normal official exchange rate source and for many OANDA or XE seem to be the easy to document if questioned later."

 

No. If you're required to file IRS Form 8938, then you must use the same Treasury Department published exchange rates as used for FBAR. (There's a limited exception for exchange rates used on your bank statements.)

 

https://www.irs.gov/instructions/i8938#idm139674972980592

Edited January 19, 2020 by taxout

[lopburi3]

4 hours ago, taxout said:

"For IRS you can use any normal official exchange rate source and for many OANDA or XE seem to be the easy to document if questioned later."

 

No. If you're required to file IRS Form 8938, then you must use the same Treasury Department published exchange rates as used for FBAR. (There's a limited exception for exchange rates used on your bank statements.)

 

https://www.irs.gov/instructions/i8938#idm139674972980592

Thanks have not been filing that as have not had large enough accounts recently.  Was thinking the exchange rate to use in report bank interest that would mostly be less than $100.  Believe normal official rates, for the day received, are still allowed for that?

[JimGant]

14 hours ago, taxout said:

No. If you're required to file IRS Form 8938, then you must use the same Treasury Department published exchange rates as used for FBAR

Only for the principal amounts reported. For taxable earnings on this principal (Section III of Form 8938) you're not restricted to Treasury or year end FX rates. Instead, you're allowed to use pretty much any rate in the ball park, as long as you're consistent -- then the dollar figure arrived at is the one you use in your Schedule B.

 

Quote

 

Quote

1040 Schedule B: The instructions Schedule B allow the use of exchange rates from any published source. This is true even if you filed an 8938 and/or FBAR using the Treasury rates.

https://judismithlaw.com/guide-to-exchange-rates-for-fbar-fatca-and-schedule-b/

For tax year 2019, with the baht appreciating throughout the year, the best exchange rate to use would be the average for the year, which is 31.032:

https://www.irs.gov/individuals/international-taxpayers/yearly-average-currency-exchange-rates

 

 

[taxout]

We don't talk much about Form 8938 here, but note that while the filing threshold is much higher than FBAR, the type of assets to be disclosed is much much broader:

 

https://www.irs.gov/instructions/i8938#idm139674973070304

 

 

[lopburi3]

32 minutes ago, taxout said:

We don't talk much about Form 8938 here, but note that while the filing threshold is much higher than FBAR, the type of assets to be disclosed is much much broader:

 

https://www.irs.gov/instructions/i8938#idm139674973070304

 

 

400,000 USD for joint return is indeed not what most of us have burning a hole in our pockets here so expect only a small percentage have requirement to file that form.  Those owning business or high end condos perhaps.

[taxout]

But for foreign residents not filing a joint return, the test is more than "$200,000 on the last day of the tax year or more than $300,000 at any time during the tax year."

 

If you're not a foreign resident, the test is more than "$50,000 on the last day of the tax year or more than $75,000 at any time during the tax year." 

 

If there's any doubt whatever whether you qualify as a foreign resident under the applicable tests, then assume the lower limit applies.

 

 

[JimGant]

10 minutes ago, taxout said:

But for foreign residents not filing a joint return, the test is more than "$200,000 on the last day of the tax year or more than $300,000 at any time during the tax year."

 

If you're not a foreign resident, the test is more than "$50,000 on the last day of the tax year or more than $75,000 at any time during the tax year." 

 

If there's any doubt whatever whether you qualify as a foreign resident under the applicable tests, then assume the lower limit applies.

 

 

Yeah, don't get confused about being a Thai tax resident by being here over 180 days -- with FATCA's "presence abroad" criteria:

 

Quote

You satisfy the presence abroad test if you are one of the following.

• A U.S. citizen who has been a bona fide resident of a foreign country or countries for an uninterrupted period that includes an entire tax year.

• A U.S. citizen or resident who is present in a foreign country or countries at least 330 full days during any period of 12 consecutive months that ends in the tax year being reported.

 

[TallGuyJohninBKK]

Meanwhile, for all those amassing their millions in TH bank accounts, keep in mind that TH bank deposit insurance D-Day is approaching this August (2020) -- 1 million baht max per accountholder per bank (not per account).

 

 

 

[TallGuyJohninBKK]

Looks like the U.S. feds have extended this year's FBAR filing deadline two extra weeks till the end of October. Get yours while they're hot!!!  ????

 

Quote

2019 FBAR Deadline now Oct 31, 2020

FinCEN originally issued a statement (screenshot below)  that the FBAR (FinCEN 114) deadline for 2019 has been moved from Oct 15 to December 31, 2020. 

On the following day, it was rescinded. Two days later, FinCEN has issued a new statement clarifying their error and moving the deadline to Oct 31, 2020.

 

FinCEN apologizes for the error and any confusion this has caused, and has coordinated with the IRS to address the concerns of filers who may have missed their filing deadline due to the October 14, 2020 message. Filers who file their 2019 calendar year FBAR by October 31, 2020 will be deemed to have timely filed. As set out in the October 6 notice, FBAR filers impacted by recent natural disasters continue to have until December 31, 2020 to file their FBARs.

 

https://app.taxesforexpats.com/articles/news/additional-time-to-file-fbar.html

 

Edited October 19, 2020 by TallGuyJohninBKK