FBAR annual reporting applies if your acct value is more than $10,000.00.

pairadimespairadimes Posts: 1 Tin ✭
Does the annual FBAR reporting requirement apply to your bitgold account balance in aggregate, i.e., the sum of all vault locations, or must each vault location be reported separately on the FBAR if its balance exceeds $10,000.00? For FBAR reporting purposes what is the proper BitGold mailing address and country code?


  • SpontaneousOrderSpontaneousOrder Posts: 307 Bronze ✭✭✭
    @pairadimes: with the caveat that I'm not a tax accountant or lawyer, and that there is still some controversy on the subject of the FBAR and Goldmoney, here is what I believe and am doing - my personal opinion.

    The FBAR applies only to U.S. citizens. I believe that, if asked, the IRS would consider Goldmoney Personal, Business, and Wealth accounts to be "foreign financial accounts" that require the FBAR to be filed. I believe that it would not be productive to get into court with the IRS and argue about whether or not the FBAR applies to Goldmoney accounts.

    The FBAR must be submitted whenever the aggregate of all foreign accounts exceeds $10,000. For example if I have $1,500 in a Goldmoney Personal account and $9,000 in a Goldmoney Wealth holding, I need to submit the FBAR. It would have two entries for my Personal and Wealth accounts (see Report of Foreign Bank and Financial Accounts (FBAR)). Although I have metal in multiple vaults, I report my entire Goldmoney Personal (formerly known as BitGold) account in a single entry on the FBAR.

    The FBAR is not filed with the normal April 15th tax return. It must be filed by the end of June for the previous tax year. The form is available here. There are choices for the offline .pdf form and the online form. I use the online form, and here's how I filled it out this past June for 2015 (updated to reflect the re-branding). Addresses are from Who We Are. Field names are in italics.

    Goldmoney Personal and Business:

    16 Type of account: other. In the box to the right: Gold bullion.
    17 Financial institution name: Goldmoney, Inc.
    18 Account number: email address used for Goldmoney Personal or Business account
    19 Address: 334 Adelaide St West Suite 305
    20 City: Toronto
    23 Country/Region: Canada (have to do this out of order to populate the "State" field)
    21 State: Ontario
    22 Foreign postal code: M5V1R4 (no spaces)

    Goldmoney Wealth:

    16 Type of account: other. In the box to the right: Precious metals and cash.
    17 Financial institution name: Goldmoney Jersey
    18 Account number: Goldmoney Wealth holding number 99-88-77-X
    19 Address: 32 Commercial Street
    20 City: St Helier
    21 State: Leave blank
    22 Foreign postal code: JE23RU (no spaces)
    23 Country/Region: Jersey

    Note: use only digits in the phone number field, and remove spaces from the postal code, or the form will not submit.
  • vroevroe Posts: 2 Tin ✭
    Actually, I think it is correct that if the account value reaches $10,000 at any time during the year, you must report. This requirement is not based on the value of the account at the time you report.
  • SpontaneousOrderSpontaneousOrder Posts: 307 Bronze ✭✭✭
    @vroe, I believe that is correct.
  • SpontaneousOrderSpontaneousOrder Posts: 307 Bronze ✭✭✭
    Update: since Goldmoney now has a U.S. subsidiary that has registered with FinCEN, I now believe that Personal and Business accounts are no longer considered foreign accounts for U.S. taxpayers, so the FBAR and Form 8938 no longer need to be filed for those accounts. They only need to be filed for Wealth holdings.
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