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TD F 90-22.1 says if there's no quarterly statement, use the largest value in the account throughout the year. It also says to use the official exchange rate at the end of the year. If my largest value is on March 15th, 2008 then why would I use the exchange rate at the end of the year? Or do they mean the average exchange rate?
IRS typically means the exchange rate on that day.
Do you really think it makes a difference?
After 20 years, I am severely cutting back on responses. Do not ask specifically for my help. There are a few others on this board that can answer most questions. All the best