Quote:
Originally Posted by PeterR
As I understand it it's not the total balance at any one time, but the total of the maximum balances at different times during the year of all the different accounts over which the US citizen has signature.
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"Q. Who must file an FBAR?
"A. Any United States person who has a financial interest in or signature authority, or other authority over any financial account in a foreign country, if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year"
FAQs Regarding Report of Foreign Bank and Financial Accounts (FBAR) - Filing Requirements
There is no intention on the part of Treasury to yield the ludicrous result that if you have $9,000 in an account and move that money to another account you are required to file because you are deemed to have $18,000 in accounts "at any time during the calendar year".
That said there is admittedly substantial ambiguity in the law and regulations and I recall that white-shoe law firms have often advised their wealthy clients to err on the side of reporting: foreign mortgages, indirect assets (at the time, "funds at Lloyd's", and so on would be reported with a disclaimer that the report was as a protective measure.