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  • IRS requirements for overseas accounts

    Do we have an accountant in the house to give opinion on this? I don't have any overseas accounts (yet) but makes sense since I can't see Uncle letting go of *any* strings to my money these days.

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    I wanted to give a heads up to the readers on the IRS reporting requirements of doing so. Since I just found out about this myself, I imagine many subscribers may not be aware that a US citizen who has CUMULATIVELY at least $10,000 (US equivalent) in foreign bank or financial accounts must report these to the DEPT of Treasury on Form TD F 90-22.1 by June 30 of the following year.

    The IRS FAQ states that a financial account "includes any bank, securities, securities derivatives or other financial instruments accounts". It appears GoldMoney accounts also "qualify" per the IRS definition because the bullion is convertible to currency. Each account must be reported including the name of the financial institution, its address, the account number(!), highest US dollar value during the year, account owners, etc.

    Not filing the form can result in severe penalties including $10,000 for non-willful filing (ignorance is not an excuse) and up to I believe $250,000 and 5 years in jail for willful non-filing. So, it seems the government wants to keep us all (or our money anyway) on a tight leash!!

  • #2
    Re: IRS requirements for overseas accounts

    I'm not an accountant, but I live overseas and have to file the form every year. What sort of "opinion" are you looking for?

    FWIW, the Treasury changed the form this year. Many more details are now required.

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    • #3
      Re: IRS requirements for overseas accounts

      Originally posted by jpatter666 View Post

      must report these to the DEPT of Treasury on Form TD F 90-22.1 by June 30 of the following year.
      FWIW, the FAQ for the form states it's due on the 30th of June. Postmark is irrelevant.

      I'm filling mine out as we speak, or, um, as I write. Thanks for the tip.

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      • #4
        Re: IRS requirements for overseas accounts
        1. What is a financial account?
          A “financial account” includes any bank, securities, securities derivatives or other financial instruments accounts. The term includes any savings, demand, checking, deposit, or any other account maintained with a financial institution or other person engaged in the business of a financial institution. Individual bonds, notes, or stock certificates held by the filer are not a financial account nor is an unsecured loan to a foreign trade or business that is not a financial institution.

        So, I infer from the above that an account at the Bullion Vault in Zurich is not a financial account. What say ye, Sharky?

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        • #5
          Re: IRS requirements for overseas accounts

          Originally posted by KGW View Post
          So, I infer from the above that an account at the Bullion Vault in Zurich is not a financial account. What say ye, Sharky?
          They aren't asking for a list of all assets held outside the country. I interpret the form as asking for info only on bank accounts and securities / trading accounts.

          Since BV isn't a bank and doesn't hold securities, my guess is that it's not the type of account they're looking for. It's also a tightly constrained account in the sense that BV only allows money to flow back to the same bank account from which it originated.

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          • #6
            Re: IRS requirements for overseas accounts

            Originally posted by Sharky View Post
            They aren't asking for a list of all assets held outside the country. I interpret the form as asking for info only on bank accounts and securities / trading accounts.

            Since BV isn't a bank and doesn't hold securities, my guess is that it's not the type of account they're looking for. It's also a tightly constrained account in the sense that BV only allows money to flow back to the same bank account from which it originated.
            isn't there an associated financial account receiving the money you send for your purchase, or does it go into bullion vault's own account?

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            • #7
              Re: IRS requirements for overseas accounts

              I called the IRS and asked the Q re: Bullion Vault. Based on the information I gave them I was told I didn't have to report the account.

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              • #8
                Re: IRS requirements for overseas accounts

                I was posting this for two reasons:

                1 ) I'm considering establishing some overseas accounts, found this and thought I'd see how other people were handling it. Also, questions about GoldMoney, BullionVault, whether they fell under the definition, etc

                2 ) I know many people here *have* recently established overseas accounts and might want to know this was required before the IRS "informed" them along with a nice penalty.

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                • #9
                  Re: IRS requirements for overseas accounts

                  The web site of Catherine Austin Fitts Solari.com has a recent public posting regarding this matter, to be found at Foreign Financial Accounts: June 30 Filing Requirement for Individuals.
                  Most folks are good; a few aren't.

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