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LearnFAQImmigrant & NRI Finance

Do I have to report foreign cryptocurrency or a foreign crypto wallet under FATCA?

Answer

The rules are still evolving, so treat this cautiously. Historically, cryptocurrency held in a self-custodied wallet was not clearly a foreign financial account for FBAR purposes, and FinCEN has signaled it intends to amend the regulations to include virtual currency accounts, so the answer may change. Crypto held on a foreign exchange that also holds fiat or acts like an account is more likely to be reportable, and it may be a specified foreign financial asset for Form 8938 depending on how it is held. Separately, all crypto transactions are taxable events reportable on your U.S. return regardless of where the wallet sits. Given the shifting guidance, the conservative approach many advisors take is to report foreign-exchange-held crypto and disclose transactions fully. Watch irs.gov and FinCEN updates, and get current advice at filing time.

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