Do US taxpayers have to report their Goldmoney account on IRS form 1040 Schedule B Part III?

metacortexmetacortex Posts: 5 Tin ✭
From the website:
At any time during 2017, did you have a financial interest in or signature authority over a financial account (such as a bank account, securities account, or brokerage account) located in a foreign country?

The first part of this question is whether Goldmoney is considered foreign. I read here that:

Goldmoney Inc. (XAU.TO), a financial technology company operating a global, 100%-reserved gold-based financial network, today announced that its wholly owned subsidiary Goldmoney USA Limited has registered with the Financial Crimes Enforcement Network ("FinCEN"), complying with the Anti-Money Laundering and Know Your Customer standards of a Money Transmitter. The registration will allow Goldmoney to extend P2P gold transfer capabilities to Network users in the United States, enabling them to send and receive title to vaulted gold on the Goldmoney Network via text, email, and other internet-based messaging platforms.

The emphasis seems to be on P2P payments, but does the subsidiary Goldmoney USA also manage the Goldmoney accounts for US taxpayers? My understanding is that if a financial institution has a subsidiary located and registered in the US then that subsidiary is not considered foreign.

But even if Goldmoney is considered foreign, maybe I don't have to report my account. The second part of my question is whether my Goldmoney account qualifies as a bank account, securities account, or brokerage account.

I have a Personal Verified account. Due to the fact that my GoldMoney account only accounts for gold owned by me and stored in a vault, it doesn't seem to be a bank account, securities account, or brokerage account.

Gold is considered a collectible by the IRS. I found this clarification on the website pertaining to IRS form 8938 (Statement of Specified Foreign Financial Assets) which does not apply to me regardless because I am below the threshold for reporting:

Q4. I directly hold precious metals for investment, such as gold, in a foreign country. Do I need to report these assets on Form 8938?

No. Directly held precious metals, such as gold, are not specified foreign financial assets. Note, however, that gold certificates issued by a foreign person may be a specified foreign financial asset that you would have to report on Form 8938, if the total value of all your specified foreign financial assets is greater than the reporting threshold that applies to you.

But what does directly held mean? Certainly, if gold were stored in my home, it would be directly held. But what if it is in a safe deposit box or a vault (as with Goldmoney), where I could arrange to pick it up?

From Wikipedia:

A gold certificate in general is a certificate of ownership that gold owners hold instead of storing the actual gold.

Is a Goldmoney account comparable to a gold certificate? If so, then it should be considered as a financial account for tax reporting purposes.

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