FACTA-- how to calculate max value

[GreenPaddy 3]

Hope I could get another good advice from you on FACTA, "Statement of Special Foreign Financial Assets".

How should we work out the maximum value of all accounts?

IRS says to file Form 8938 if you are Married Filing Jointly:

Married taxpayers filing a joint income tax return and living in the US: The total value of your specified foreign financial assets is more than $100,000 on the last day of the tax year or more than $150,000 at any time during the tax year

I know my total value of foreign financial assets wasn't over $100,000 on the last day of 2015.

But how do you understand "more than $150,000 at any time during the tax year"?

I have 3 bank accounts. I'm sure the total value of all accounts never exceeded $150,000 at any one point of last year.

When I look at Form 8938, in Part V Line 4, it asks "Maximum value of account during tax year".

If I fill out the max value of each account during the year and add them all, it will exceed $150,000 because it's not the total at one point but multiple points.

Account A: max value $70,000 - January

Account B: max value $35,000 - March

Account C: max value $50,000 - October

total: $155,000

It will exceed the threshold only because I moved my money between accounts.

Should I file Form 8938?

Another question: Should I report my forex account in Form8938?

Sorry I'm going nuts about this tax return. It's so hard to understand the system.

Maybe I should call and ask IRS.

I just came here on K-1, married, filed AOS, obamacare, taxes... it's like swimming in a storm.

Thank you for any insights.

[vanlaria 5]

I HATE FATCA it's the stupidest thing... I used to work at a Canadian bank and they forced us into all this compliance, but gave almost no instructions!!! Soooo many categories to choose from, no idea what to do if someone is a citizen but doesn't have an SSN (like if they have a citizen parent, but have never lived in the USA...), really awkward to tell current clients 'Hey I know you've had an account here for decades but since we've identified you as American we need your SSN or we'll have to close it sorry!'

GRRRRR makes me mad just thinking about it.

Anyway, I think since your accounts never exceeded 150,000 on any one day of the year, you probably don't need to file form 8938, but I'm no expert, so I'd call if you're unsure. Best of luck!!!

[GreenPaddy 3]

Thanks vanlaria, it helps to know even bankers feel dilemma about it.

Does anybody know how to calculate the max amount?

Will it be OK if I add up figure based on one day during the year??