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| I'm still not convinced... | |
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The FBAR requirement is addressed to the location of the account, not the subsequent location of the funds. The FBAR (form TDF-90) instructions state:
"the
geographical location of the account, not the nationality of the financial entity institution in which the account is found determines whether it is in an account in a foreign country. Report any financial account...located in a foreign country, even if it is held at an affiliate of a United States...financial institution."
Further, as a practical matter, the only cost of reporting the IB(UK) info is measured in minutes, while the cost of arguing with the IRS is substantially more, and the cost of losing that argument is painful.
Does that help ?