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February 21, 2020

For 2019 You Will Not Have to report Vitural Currency held in an Offshore Account on Form 114 - This Rule May Change in the Future

For this year the FinCEN has stated: “Currently the FBAR (Form 114) regulations do not define virtual currency held in an offshore account as a type of reportable account. For this reason, at this time, virtual currency held in an offshore account is not reportable on the FBAR.” 
However for the future you need to follow this issue since the FINCEN position on virtual currency accounts is very likely to change at some point.
You can find FinCEN’s letter of January 22, 2020 in Appendix III of the Government Accountability Office report Virtual Currencies: Additional Information Reporting and Clarified Guidance Could Improve Tax Compliance .
We can help you with your Form 114 fiing, questions and other international and expat tax questions.  Email us at and go to our website at 

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