Reporting credit cards and lines of credit on FBAR and FATCA

[puzon23]

Hi All,

I'm trying to clear up some confusion I have regarding foreign reporting requirements.

I still have some financial accounts back in Canada which I will have to report for FBAR. Besides the typical checking accounts I also have a couple of credit cards and lines of credit.

Those are typical credit cards and lines of credit in a sense that you simply either borrow money form them or use the credit card for purchases and then pay them back with interest. Also, those credit cards have a cash back feature where at the end of the year I get some cash back which I actually did for 2016.

So, with all that in mind, do I have to report these credit cards and lines of credit on my FBAR?

Thank you for help!

[rlb]

No, they are not reported, since they represent money you owe. The one exception would be if you (probably accidentally) overpaid say a credit card so that it has a positive balance. Then it would be reported that year.

[puzon23]

Thanks for the answer. That's a good point. I believe that I actually do have one of them that I overpaid by accident and it has a positive balance that is owned to me. It might something crazy little like $4 but I'd rather report it than find out that I can be hit with penalties for not doing so.

Thanks!

[MGeorge]

I read somewhere, but can't substantiate, that credit cards and lines of credit have to be reported unless there is an automatic refund to you if you overpay. In other words, if the balance goes positive, they send you a check automatically. None of my accounts do this. I don't report credit cards or lines of credit, perhaps I should technically, but I don't think they'd care.

[MGeorge]

Hello again,

This might be helpful. There is a statement that "unsecured" credit card accounts are not generally reportable as a financial account.

https://www.irs.gov/pub/irs-wd/0603026.pdf