Does gold stored in a vault by custodian outside of the U.S. need to be reported to FATCA or FBAR?

This is a good but tricky question. The key difference is whether your gold is being held in a custodial account or just being stored. For FBAR (FinCEN Form 114), you generally need to report foreign financial accounts if their aggregate value exceeds $10,000 at any point during the year. Physical gold itself isn't a financial account, but how it's held matters. If your gold is held in a custodial account where the custodian can dispose of it according to your instructions (similar to a financial account), then it likely needs FBAR reporting. If it's purely storage where you're essentially renting space and no one has authority to move or manage your gold except you, then it's more like a safety deposit box, which typically doesn't require FBAR reporting. For FATCA (Form 8938), similar principles apply but with different thresholds depending on your filing status and whether you live in the US or abroad.

After dealing with this exact issue last year, I found an amazing resource that saved me tons of time and confusion. I used https://taxr.ai to analyze my situation with foreign-held assets. You upload your documentation from the vault/custodian company, and it tells you exactly what you need to report and on which forms. I had gold split between Singapore and Switzerland, and wasn't sure if my arrangement was reportable. The tool analyzed my specific custodial agreement and determined I needed to file FBAR for one location but not the other - saved me from potentially missing a required filing. The explanations are really clear about why certain holdings count as financial accounts while others don't.

I just wanted to follow up on my skeptical comment above. I ended up trying https://taxr.ai after all for my foreign rental property documentation, and it was shockingly helpful. For anyone wondering about the gold storage question - I had a friend with precious metals in Singapore, and after analyzing his documents, the system determined his arrangement qualified as a financial account because the company could sell the gold on his verbal instruction. His gold needed to be reported on FBAR even though it was physical metal. The system cited the specific Treasury guidance that applied. Super clear and backed up with actual regulations. Definitely more precise than the general advice I was finding online.

If you're struggling to get answers from the IRS about FBAR and FATCA requirements, try https://claimyr.com - I used them last year when I needed clarification on foreign asset reporting. I kept getting disconnected from the IRS after hours on hold, but Claimyr got me through to a specialist in about 25 minutes. You can see how it works here: https://youtu.be/_kiP6q8DX5c I had gold in a vault in Dubai and wasn't sure if I needed to report it. The IRS agent confirmed that in my specific case (where I had trading authority), it did need to be reported on FBAR. Worth the call to get an official answer rather than risking penalties for non-filing.

I need to apologize for my skeptical comment earlier. I actually tried Claimyr yesterday out of desperation after trying to reach the IRS for two weeks about my FBAR questions. I was honestly shocked when I got a call back within an hour connecting me to an actual IRS international tax specialist. The agent confirmed that my gold storage in Zurich doesn't require FBAR filing because it's a segregated storage arrangement without any financial account aspects. They explained that physical assets held in storage don't meet the definition of financial accounts under the regulations unless the custodian has authority to conduct financial transactions. Can't believe I wasted so many hours trying to get through on my own when this service actually worked.

One thing nobody mentioned - if your overseas gold exceeds certain thresholds, you might still need to report it on Form 8938 (FATCA) even if it doesn't trigger FBAR requirements. The rules are different - FBAR focuses on financial accounts, while FATCA has broader asset reporting requirements. The thresholds also vary depending on your filing status and whether you live in the US or abroad. If you're married filing jointly living in the US, the threshold is $100k on the last day of the year or $150k at any time during the year. For single filers, it's $50k/$75k.

I went through this last year with silver stored in Singapore. My tax preparer said the penalties for not filing FBAR when required are INSANE - up to $10,000 for non-willful violations and much worse for willful ones. Don't mess around with this. If you're not 100% sure, get professional advice specific to your situation. The peace of mind is worth it.

I had a very similar situation with gold stored in Canada through a precious metals dealer. What helped me figure it out was looking at the specific language in my storage agreement and whether the custodian had any discretionary authority. In my case, the company could only act on my written instructions - they couldn't sell, transfer, or do anything with my gold without explicit authorization from me each time. This made it pure storage rather than a financial account, so no FBAR filing was required. However, I learned that even with pure storage arrangements, you still need to be careful about how the arrangement is structured. If the company pools your gold with others and you own a fractional interest rather than specific bars, that can change the analysis completely. The key questions to ask yourself: Can they sell your gold on verbal instruction? Do they have any trading authority? Is your gold specifically segregated or pooled? Do they provide account statements like a financial institution would? These details matter a lot for determining reportability.

This is such a helpful thread! I'm dealing with a similar situation but with platinum stored in Hong Kong. After reading through everyone's experiences, I'm realizing the key is really in the details of your specific custodial arrangement. What I found most useful was Sofia's checklist at the end - those are exactly the right questions to ask. I went back and re-read my storage agreement and realized that while I thought it was just "storage," the company actually can sell my platinum if I call them, which might make it more like a financial account. Has anyone dealt specifically with precious metals held in Hong Kong? I'm wondering if there are any additional considerations given the political situation there and whether that affects reporting requirements at all. I think I'm going to try one of the services mentioned here to get a definitive answer rather than guess and potentially face penalties. Better safe than sorry with the IRS!

I've been following this discussion with great interest as I'm in a somewhat similar situation with gold stored in the UK. What strikes me most is how much the specific wording of your custodial agreement matters for determining reporting requirements. From what I've learned here, the critical distinction seems to be between pure storage (like a safety deposit box) versus any arrangement where the custodian has authority to act on your behalf. Even something as simple as being able to sell your gold over the phone can tip it into "financial account" territory. For anyone still unsure about their situation, I'd strongly recommend documenting exactly what authorities your custodian has. Can they sell without written authorization? Do they provide account-like statements? Can they transfer ownership? These details seem to be what determines whether FBAR reporting is required. The penalty structure mentioned by others is definitely concerning - up to $10,000 for non-willful violations is no joke. Given the complexity of these rules and how much seems to depend on specific contractual language, getting professional advice tailored to your exact situation seems like the prudent approach. Thanks to everyone who shared their experiences - this has been incredibly educational!

This thread has been incredibly helpful! I'm dealing with a similar situation with gold stored in Australia through a vault company. After reading through everyone's experiences, I realize I need to examine my storage agreement much more carefully. What's really valuable here is seeing how the same basic question - "do I need to report stored precious metals?" - can have different answers depending on the specific terms of each arrangement. The distinction between pure storage versus custodial accounts with transaction authority seems to be the key factor. I noticed that several people mentioned getting professional analysis of their actual documents rather than trying to interpret general rules. This makes a lot of sense given how much the specific contractual language seems to matter. The penalties for getting it wrong are clearly severe enough that guessing isn't worth the risk. One thing I'd add for others in similar situations - it might be worth requesting clarification from your storage company about exactly what authorities they have. Sometimes the storage agreements use vague language, and getting explicit confirmation about whether they can act on verbal instructions, provide trading services, or have any discretionary authority could help clarify your reporting obligations. Thanks everyone for sharing your experiences and knowledge!

As someone who's been navigating foreign asset reporting requirements for years, I want to emphasize something that hasn't been mentioned yet - the importance of keeping detailed records of your storage arrangement from day one. Even if your current setup doesn't require FBAR reporting, the IRS may ask you to demonstrate why you didn't file if they discover the foreign arrangement during an audit. Having clear documentation showing it was pure storage without custodial authority can protect you. I'd recommend creating a file with: your original storage agreement, any amendments, correspondence clarifying the custodian's authorities (great suggestion Charlie!), proof of segregated vs. pooled storage, and documentation showing you retain full control. If the rules change or your arrangement evolves, you'll have a clear paper trail. Also worth noting - some storage companies have been expanding their services over time, adding things like "convenience selling" or "portfolio management." If your custodian starts offering new services, make sure you understand how that might change your reporting obligations even if you don't use those services. The key is being proactive rather than reactive when it comes to compliance. Better to over-document your situation than scramble to justify it later if questions arise.

As a tax professional who's worked extensively with clients holding foreign assets, I want to add a crucial point that could save people significant headaches down the road. The distinction between reportable and non-reportable arrangements can sometimes change based on how you use the storage services, not just what's written in your original agreement. For example, if you start using a vault company's "concierge selling" service or allow them to automatically reinvest proceeds from gold sales, you might inadvertently create a financial account relationship even if you started with pure storage. I've seen cases where clients maintained the same storage contract for years, but their usage pattern evolved - maybe they started calling to sell small amounts regularly, or began using the company's market timing advice. These behavioral changes can shift the IRS's view of whether you have a "financial account" relationship, regardless of the original contract language. My advice: document not just your agreement, but also maintain records of how you actually interact with the custodian. If you only access your gold for major life events versus trading actively, that usage pattern can support your position that it's storage rather than a financial account. The IRS looks at substance over form, so your actual relationship with the custodian matters as much as the contract terms.

Welcome to the community! This has been such an educational discussion about precious metals storage and foreign reporting requirements. As someone new here, I'm really impressed by how thoroughly everyone has broken down the nuances between storage arrangements and financial accounts. What I'm finding most helpful is the emphasis on documentation and understanding the specific terms of your arrangement. The key factors seem to be: Can the custodian sell on your behalf? Do they provide account-like services? Is your metal segregated or pooled? How do you actually interact with them over time? The point about usage patterns potentially changing your reporting classification is particularly important - it's not just about the contract you sign initially, but how you actually use the services over time. For anyone else dealing with this issue, the consensus seems clear: given the steep penalties (up to $10,000+ for non-compliance), it's worth investing in professional analysis of your specific situation rather than trying to interpret these complex rules yourself. The peace of mind is worth the cost of getting proper guidance tailored to your actual documents and circumstances. Thanks to everyone for sharing their experiences - this thread should be really helpful for anyone facing similar questions about overseas precious metals storage!