Keep account balances and transfer records separately. For FBAR, distinguish the aggregate amount used to determine filing requirements from the maximum value reported for each account.
1. Identify Each Account’s Maximum Value
Review balances throughout the year, recording each account’s maximum value and date. Do not rely solely on year-end or post-transfer balances.
Funds received from another account remain part of the receiving account’s balance.
Reference: FinCEN — Reporting Maximum Account Value
2. Avoid Double Counting When Assessing the Threshold
Adding account maximums can count the same transferred funds twice. IRS guidance states that money moved between foreign accounts during the year is counted only once when determining the aggregate threshold.
Retain statements linking withdrawals and deposits.
Reference: IRS — FBAR: Aggregate Value Over $10,000
3. Report Each Account’s Maximum When Filing
Suppose $20,000 moves entirely from Account A to Account B, with no other funds or balance changes.
| Item | Account A | Account B |
|---|---|---|
| Before transfer | $20,000 | $0 |
| After transfer | $0 | $20,000 |
| Individual maximum | $20,000 | $20,000 |
If FBAR filing is required and both accounts are reportable, each generally shows $20,000. Do not reduce Account B’s maximum to zero because the funds came from Account A.
The reported maximums total $40,000, but this does not mean you held that amount simultaneously.
4. Review Currency Conversion and Form 8938
For FBAR, generally determine maximum values in local currency and convert using the Treasury’s calendar year-end exchange rate, rather than the transfer-date rate.
Reference: FinCEN — Reporting Maximum Account Value
Form 8938 has separate threshold, valuation, and joint-ownership rules. Review it independently rather than simply copying FBAR figures.
Reference: IRS — Instructions for Form 8938
Records to Gather
- Account statements and balances
- Transfer, withdrawal, and deposit dates
- Sending and receiving accounts
- Amounts, currencies, and fees
- Maximum annual and year-end values
- Ownership and signature authority
We review balances and transfers to determine filing requirements and reportable values. Please provide only an overview initially; confidential records should be shared through the method we specify separately.
This answer provides general information for individuals. Currency movements, transfer timing, ownership, and reporting periods may require additional review.
Information reviewed: October 14, 2026
