How should gold in online account be classified for Fincen?

Potassium · Post by **Potassium** » Thu Jun 23, 2016 11:23 am

I've got an account with an online company (www.bullionvault.com) where I'm registered with a non US address.

This site allows you to buy/hold/sell gold, at any point my account may hold a certain amount of gold and a certain amount of cash.

Just wondering how this should be reported on a FinCen form. Its not a bank, so I guess I'll choose the "Other" for it, but then how should that be further described?

nelsona · Post by **nelsona** » Thu Jun 23, 2016 12:00 pm

Bullionvault is simply a foreign investment firm based in London.
never choose other.

Potassium · Post by **Potassium** » Fri Jun 24, 2016 10:45 am

Thanks but is an investment firm considered a Bank or Securities for the form?

When you say never choose other, do you mean specifically for this case, or in general when using the FinCen form?

Last year I had my FinCen prepared by a cross-border accountancy firm and they classified some UK pension accounts as Other. Is that correct?

Potassium · Post by **Potassium** » Fri Jun 24, 2016 11:20 am

Also is it correct to classify an RRSP to be of type Other?

Thanks

nelsona · Post by **nelsona** » Fri Jun 24, 2016 3:43 pm

The fact that the account is an RRSP doesn't define what TYPE of account it is. If it is held at a broker or a mutual fund firm, it is a securities account, if it is held at a bank (in cash or gics) it is a bank account.

It is rarely other.

Potassium · Post by **Potassium** » Mon Jun 27, 2016 11:11 am

Thank you

"Bullionvault is simply a foreign investment firm based in London."

On FinCen there are only the 3 choices or Bank/Securities/Other. You indicated Other should not be chosen for Bullionvault, and its not a Bank, therefore presumably an investment firm is a security, and that is what Bullionvault should be classified as?

nelsona · Post by **nelsona** » Mon Jun 27, 2016 12:08 pm

Right. Investment = securities.

nelsona · Post by **nelsona** » Mon Jun 27, 2016 12:11 pm

As to your UK pension accounts:
Do you control these accounts? If not then it should not be on FBAR. It would fall under FATCA, perhaps.

If you do control it, then you would know what type of holdings it has, and would choose between bank and securities.

Potassium · Post by **Potassium** » Tue Jun 28, 2016 10:39 am

I also have a Canadian RRSP, however AFAIK I don't manage it. Its a managed fund account, managed by portfolio managers, I have no ability to control it. Does that mean such types of RRPSs should also therefore not appear on FBAR?
If that is what control means.

nelsona · Post by **nelsona** » Tue Jun 28, 2016 10:45 am

I said CONTROL, not manage.

Obviously you don't manage the funds within your RRSP. Same at a bank, they take your money and invest it as they wish.
However, you do control whether you put money in, and when you take money out. That is control, and the RRSP account is clearly a securities account.

Let's not make this hard people.

Frankd1 · Post by **Frankd1** » Tue Jun 28, 2016 9:42 pm

If an RRSP has been incorrectly listed as "other" when it should have been listed as "securities", going forward to next years FBAR filing would it be ok to simply change it to the correct category of securities? Would you need to go back and file amended FBAR reports to correct the previous few years or, leave those be and carry on correctly next year?

nelsona · Post by **nelsona** » Wed Jun 29, 2016 8:37 am

Again, they just want to know about the account. let's not overthink this.

nelsona · Post by **nelsona** » Wed Jun 29, 2016 8:38 am

When you write "other", you then have to explain how the account is not a bank or security account. Curious how all these experts are explaining their choice of other.