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Changes To U.S Reporting Requirement For Foreign Banks

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It looks like the US government is listening to feedback on the FATCA legislation from foreign banks, consumer groups, and individual tax-payers. The original legislation really didn't differentiate between a multi-millionaire living in American attempting to hide assets in foreign banks to evade taxes, and an expat pensioner on a fixed income and limited funds who has a bank account in the country in which he lives. But there has been some proposed changes to the FATCA guidelines that should set the majority of US expats minds more at ease. The lower thresholds for reporting (originally $50,000) have been raised as follows:

U.S. Citizens Living Abroad:

For U.S. citizens who are considered by the IRS to be foreign residents for the entire tax year or who meet the physical presence test for living in a foreign county, the new limits are:

• Single: Aggregate foreign assets of USD 200,000 on the last day of the year or USD 300,000 at any time during the year.

• Married Filing Jointly: Aggregate foreign assets of USD 400,000 on the last day of the year or USD 600,000 at any time during the year.

Resident U.S. Citizens and Resident Aliens:

• Single: Aggregate foreign assets of exceeding USD 50,000 on the last day of the year or USD 75,000 at any time during the year.

• Married Filing Jointly: The threshold is USD 100,000 on the last day or the year or USD 150,000 at any time during the year.

This also lessens the reporting requirements for the banks, so if you don't exceed these thresholds, then neither you nor the banks have to report your accounts (but you still have to file a TD F 90-22.1 with the US Treasury for any aggregate amount over $10,000).

Additionally for the banks, they are only asked to do "electronic searches" for accounts with funds between the threshold amounts stated above and $1 million. Starting 2013, the US would request the account holders name, address, and account balance. Starting 2016 they would additionally request interest income. For accounts over $1 million, the IRS would require more detailed information.

So, I'm hoping from the bank's standpoint, if a US expat bank customer does not meet the reporting thresholds, it should stay business as usual. If banks chose to modify their banking policy for US expats, they could simply cap deposits at the reporting thresholds to avoid the necessity of reporting at all. So hopefully, expat retirees like myself who have limited savings and fixed incomes will not be affected. I guess we'll know by next year.

It will be interesting to see how Thai financial institutions chose to address FATCA required reporting.

I suggest performing your own due diligence. I pulled my sources from the following:

http://www.washingto...D4zQ_story.html

http://www.creveling...-form-8938.html

http://www.deloitte....a56f00aRCRD.htm

I'd also suggest consulting your own tax adviser. Overall, I think this is good news for the majority of the US expat community.

Good info to know....thanks.

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