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FinCEN: Cryptocurrency Currently Not FBAR Reportable

June 20, 2019

Tax practitioners and taxpayers alike have long grappled with whether virtual currency, aka cryptocurrency, is reportable for purposes of FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Normally, the value of fiat currency, i.e., U.S. dollars and other assets held by a foreign financial institution (FFI) on behalf of a taxpayer, is reportable on U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) Form 114 when the aggregate value of all offshore accounts exceeds $10,000 at any point during the tax year. 

The American Institute of CPAs (AICPA) Virtual Currency Task Force reached out to the FinCEN to help practitioners answer this question. FinCEN responded that regulations (31 C.F.R. §1010.350(c)) do not define virtual currency held in an offshore account as a type of reportable account. Therefore, virtual currency is not reportable on the FBAR, at least for now, although this may change in the future. Read more at The Tax Adviser.