the highest aggregate balance of the year

[tsanah]

what is the highest aggregate balance of all accounts, and how to calculate when these accounts have different time statements (mutual funds quarterly reported or whenever there is a transaction, GIC has no statement except renewal or mature notice). How about selling mutual funds and then deposit into a saving account and later to make a GIC ?

Suppose I have three accounts Mutual fund M(t), Saving account S(t), and a GIC account G(t)

The highest aggregate balance HAB(t) = Max {M(t) + S(t) + G(t)} NOT Max(M(t))+Max(S(t))+Max(G(t)) , Am I right ?

If so,

HAB(t) should be calculated based at a time when HAB(t) has highest value.

So, when mutual fund is sold at t1 at value M, M(t)=0 (t>t1), and put the money into saving account S(t1) = M. S(t)=0 (t<t1). After a few days in the saving account it earns interets IntS and then convert a GIC at t2, G(t) = M+IntS , G(t) = 0 t<t2. Suppose by the end of the year, GIC earns interest IntG,

Now HAB(t) = Max {M+IntS+Int, Max(M(t))}

So, there is no need to show how the money is transfered, rather, it is well defined in math term of HAB, because all accounts are funtion of time, and HAB is the highest value of addition of all accounts at a specific time.

Correct me, please

[nelsona]

Whata a pointless exercise.
If you have accounts that total *close* to $10K, put them all in FBAR. If the toatl of your accounts is *well below* $10K, don't file FBAR.

[tsanah]

[quote="nelsona"]Whata a pointless exercise.
If you have accounts that total *close* to $10K, put them all in FBAR. If the toatl of your accounts is *well below* $10K, don't file FBAR.[/quote]

sorry this might be annoying to some readers. i am also taking about penalty on ovdi/ovdp like 20% on the HAB. I saw one Q/A about transfer fund between accounts, how would they consider the total value. The IRS's position is that the burden of proof on the taxpayer that if the fund is the same source, it should not be counted twice. I think that kind proof is hard to get, and you can't ask bank to say "the certain amount money in account B is from account A etc". So, I just want to know the real def of HAB (highest aggregate balance of mutiple accounts.

[nelsona]

File the FBAR. You won't be penalized if you file without being asked to file.

You are about the 1000th person on this board to back-file and not one has been fined.

[tsanah]

[quote="nelsona"]File the FBAR. You won't be penalized if you file without being asked to file.

You are about the 1000th person on this board to back-file and not one has been fined.[/quote]

Thanks... I have two kinds fund in Canada, around 50K of RRSP, and small amount non-RRSP. I keep a saving account just in case visiting Canada. So It makes a bit complicated with RRSP also in the total value.

[nelsona]

What is complicated?

Nowhere on the FBAR forms is aggregate value requested. Max value of each account is requested. Surely you can come up with that without a math formula.

You need to file FBAR, which takes 5 minutes.

[nelsona]

RRSP IS included in the FBAR requirements, no matter what you may have heard.

Less reading and posting, more filing.

[nelsona]

and stop 'quoting', it doesn't work. I know what I wrote.

[tsanah]

thanks and forgive me for being a jerk...

if i understand correctly,

For RRSP, i should just go ahead file f1040x, f8891 and FBAR for RRSP back to 6 years (f1040x is needed for f8891)

As for non-RRSP, I go to ovdi, since it is so small, i really don't care how they want to punish me.

Right ?

[nelsona]

ovdi won't apply.

But if it did, it would apply to ALL your holdings including RRSP. FBAR should include every single account you ever had in each of the past 6 years. Period.

Not filing 8891 would bring about additional penalties, apart from FBAR.

Get the point? File yesterday and forget ovdi.

[tsanah]

ovdi Q/A said they treat accounts differently based on tax issue. If no tax owed, no penalty.

RRSP without election is a tax issue, if back file is allowed, it is not a tax issue.

If RRSP only, back file seems the right solution.

RRSP plus non-RRSP (regardless the amount), it is the problem i have now.

I had my ovdi submit yesterday. Now it is just how to make RRSP a non-tax issue.

[ikeaidea]

OVDI will not take care of your case soon. A lot of case from 2009 OVDI is still pending.

I agree with Nelsona, no filing means penalty. Go ahead to file 1040X anyway, forget the OVDI. Also, file TD-F to Detrioit. It doesn't hurt you but earn you time aheard of IRS realize the accounts.

[nstudent]

tsanah, have you heard back from IRS?

To those who have backfiled FBAR: how do you write the explanation to IRS?

[tsanaha]

TO nstudent,


I am tsanah -- now tsanaha (i lost my access on tsanah).

I am in OVDI 2011 with both RRSP and non-RRSP problem. Talked to OVDI hotline and was told that RRSP can be excluded from FBAR penalty if it has never been cashed out. However, I was also told that IRS might change position in order to max their "profit" to get more money on penalty.

Anyway, I submitted 8891 (7 years for my TD bank RRSP because TD has only up to 7 yeras records) along with 1040x, FBAR....

It has been over 6 weeks now , a big check (all tax due plus FBAR penalty) has been cashed by IRS --but I have not yet heard them back -- and I am still waiting for an agent to look at my case

I don't think anyone with only RRSP problem should get into OVDI --

I will share my story with all who might be in the same situation..

[tsanaha]

http://www.chamberlainlaw.com/assets/attachments/S7.pdf