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Kai Santiago

How to determine the maximum value for FBAR reporting on foreign accounts with stocks?

This is my first time dealing with FinCEN Form 114 (FBAR) and I'm trying to figure out exactly what information I need to gather. I understand the basics - I need to report the maximum value of each foreign account I have during the year. For my regular foreign bank accounts, this is pretty straightforward. I get monthly statements that show all transactions and the resulting balance after each one, so finding the highest value is just a matter of reviewing these statements. Where I'm confused is with my overseas retirement account that contains various stocks and ETFs. The values fluctuate daily, but my statements only show monthly opening/closing balances plus any transactions I personally made. Is it acceptable to just use the highest month-end balance for FBAR reporting purposes? Or do I need to somehow track down the daily maximum values for each security throughout the year? If I do need daily maximums, is there a preferred source for this pricing data that the IRS or FinCEN considers acceptable? Would using maximum prices from Yahoo Finance be sufficient, or is there some official source I should be using instead? I want to make sure I'm compliant without making this unnecessarily complicated. Any guidance would be appreciated!

Lim Wong

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For FBAR reporting on accounts holding securities like stocks and ETFs, you generally don't need to track daily fluctuations. The FinCEN guidance allows for reasonable methods to determine the maximum value. Most people use the highest month-end balance from their statements as the maximum value for FBAR reporting purposes. This is considered a reasonable method and is much more practical than trying to track daily values throughout the year. If you receive monthly statements for your retirement account showing the month-end balances, you can simply review all 12 statements and report the highest value. Make sure you convert to USD using the exchange rate on that particular date. The important thing is to be consistent with your method and to make a good faith effort to report the maximum value. The IRS understands that exact daily tracking isn't feasible for most account holders.

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Dananyl Lear

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Thanks for this info! Does this rule apply even for accounts that might have significant intra-month volatility? I have a similar situation but with some tech stocks that can swing 20% within a month. Would hate to underreport by using just the month-end balance if that's not actually compliant.

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Lim Wong

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Yes, this applies even to accounts with volatile holdings. The FBAR instructions acknowledge that determining the exact maximum balance may be difficult for certain accounts. Using the highest month-end balance is generally considered acceptable even with volatility, as long as you're consistent in your approach. If you're particularly concerned about significant intra-month movements, you could consider using the highest balance reported on any statement during the year, even if it's a mid-month statement. But for most individual filers, the highest month-end balance method is sufficient and widely accepted for FBAR compliance.

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After struggling with similar FBAR questions last year, I found a tool that saved me hours of work. I used https://taxr.ai to analyze all my foreign account statements at once. It automatically extracted all the monthly balances, identified the highest values, and even handled the currency conversion calculations. The best part was I could upload PDFs of all my statements (even the ones in foreign languages) and it pulled out the key data. For my brokerage account, it used the month-end balances which my tax advisor later confirmed was perfectly acceptable for FBAR reporting.

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Ana Rusula

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Does this tool handle different account types? I have regular bank accounts, but also pension funds and some investment accounts in Europe. Would it recognize all those different statement formats?

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Fidel Carson

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Sounds interesting but I'm a bit skeptical. How does it handle currency conversion? Does it just use the year-end rate or does it actually match the correct exchange rate to each month's balance?

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It handles pretty much all types of accounts - checking, savings, investment accounts, pension funds, etc. I had accounts from three different countries with completely different statement formats, and it worked for all of them. You just upload your documents and it figures out what they are. For currency conversion, it uses the correct Treasury Department exchange rates for each specific date of your balance. So if your highest balance was in March, it applies the March exchange rate, not the year-end rate. It also keeps track of which rate was used so you can verify everything. That was actually one of the most helpful features since calculating each conversion manually was really tedious before.

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Ana Rusula

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If you're having trouble getting answers from the IRS about FBAR requirements, I recommend using https://claimyr.com to actually get through to a person at the IRS. I spent weeks trying to get clarification about reporting requirements for my foreign mutual funds and kept hitting automated systems. Through Claimyr I got connected to an IRS agent in about 20 minutes who confirmed that for investment accounts, using the highest month-end balance is perfectly acceptable for FBAR purposes. You can see how it works here: https://youtu.be/_kiP6q8DX5c Really helped me clear up my confusion and file with confidence rather than stressing about whether I was doing it right.

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Xan Dae

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It works by essentially handling the hold time for you. The service calls the IRS and navigates the initial phone tree, then waits on hold until an actual human agent picks up. When that happens, you get a call connecting you directly to that agent. So instead of you personally waiting on hold for hours, their system does it for you. I was surprised too, but it actually works exactly as advertised. You don't have to take my word for it though - I was skeptical at first too. But after trying to call the IRS directly four different times and never getting through, I was desperate for answers about my FBAR situation.

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I need to eat my words about Claimyr. After posting my skeptical comment yesterday, I decided to try it myself since I've been trying unsuccessfully to get clarification on FBAR requirements for weeks. I was honestly shocked when I got a call back connecting me to an actual IRS representative after about 35 minutes. The agent was able to confirm that for retirement accounts with securities, the highest month-end balance is perfectly adequate for FBAR reporting. Saved me hours of research and worry, and probably saved me from overreporting too. I was about to try tracking down daily values for all my securities which would have been a huge unnecessary hassle.

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Thais Soares

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Something else to consider - the FBAR instructions specifically state you should use the "maximum value" of your account, not the balance. For investment accounts, this means you should report the highest fair market value during the reporting period. In practice, most people use the highest month-end balance from their statements, but technically if you know the account was worth more at some point during the month, you should report that higher value. That said, I've never heard of anyone getting in trouble for using month-end statements as long as it was a reasonable good faith effort.

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Kai Santiago

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Thanks for this clarification. Do you know if there's any specific guidance from FinCEN about securities accounts specifically? I'm trying to find official documentation but much of what I find seems geared toward regular bank accounts rather than investment portfolios.

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Thais Soares

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There isn't super specific guidance for securities accounts in the official instructions, which is why this is confusing for many people. The general rule is that you should use a "periodic account statement" to determine the maximum value. For securities accounts, your monthly statements qualify as periodic statements. The FinCEN Form 114 instructions (available on the BSA E-Filing website) state that you should "determine the maximum value of a financial account based on the periodic statements provided for the account." This is why using the highest month-end balance from your statements is widely accepted. If you want to be extra cautious, you could review any transaction confirmations or other statements that show intra-month values, but most tax professionals consider the month-end statement method to be compliant with the requirements.

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Nalani Liu

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Quick tip from someone who's been filing FBARs for years - don't overthink this! The key is making a reasonable, good faith effort. I've always used month-end statement values for my investment accounts and never had an issue. Remember that FBAR penalties are primarily designed to catch people hiding assets, not to punish minor valuation differences from people trying to comply. As long as you're making an honest effort to report your accounts, you'll be fine.

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Axel Bourke

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Exactly this! I wasted so much time my first year trying to calculate the perfect maximum values. The IRS doesn't expect you to track daily fluctuations for investment accounts - they just want to know about the existence of the accounts and a reasonable approximation of their maximum value.

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Miguel Silva

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As someone who's dealt with this exact situation, I can confirm that using the highest month-end balance from your retirement account statements is absolutely fine for FBAR reporting. The FinCEN instructions are designed to be practical - they understand that most people don't have access to daily valuations for their investment accounts. One thing that helped me was organizing all my statements chronologically and creating a simple spreadsheet with the month-end balance for each account. This made it easy to identify the maximum values and also gave me documentation to keep with my records. For currency conversion, make sure you use the Treasury Department's published exchange rates for the specific date of your maximum balance, not just a random date or year-end rate. The rates are available on the Treasury website and using the official rates helps ensure compliance. Don't stress too much about this - the fact that you're asking these questions shows you're making a good faith effort to comply, which is really what matters most.

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Mei Wong

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This is really helpful advice, especially about organizing the statements in a spreadsheet! I'm just starting to gather all my documents for FBAR filing and feeling a bit overwhelmed. Do you have any suggestions for what columns to include in the spreadsheet beyond just the month-end balances? I'm thinking account name, currency, balance, USD conversion rate, and converted USD amount - but wondering if there's anything else I should track to make the actual filing process smoother.

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Ally Tailer

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Your spreadsheet approach sounds great! I'd suggest adding a few more columns to make filing even smoother: "Account Type" (checking, savings, investment, etc.), "Financial Institution Name", "Country", "Account Number" (last 4 digits for your records), and "Maximum Balance Date" (the specific date when that balance occurred). Also consider adding a "Notes" column for any special circumstances - like if you used a mid-month statement instead of month-end, or if there were any unusual transactions that month. This documentation will be super helpful if you ever need to reference your methodology later. One more tip: include the source of your exchange rate (Treasury.gov) and the specific URL or date you accessed it. Makes everything much more organized for next year's filing!

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