FinCEN Notice 2020-2, here, provides (cut and pasted in full):
Report of Foreign Bank and Financial Accounts (FBAR) Filing Requirement for Virtual Currency FinCEN Notice 2020-2 Currently, the Report of Foreign Bank and Financial Accounts (FBAR) regulations do not define a foreign account holding virtual currency as a type of reportable account. (See 31 CFR 1010.350(c)). For that reason, at this time, a foreign account holding virtual currency is not reportable on the FBAR (unless it is a reportable account under 31 C.F.R. 1010.350 because it holds reportable assets besides virtual currency). However, FinCEN intends to propose to amend the regulations implementing the Bank Secrecy Act (BSA) regarding reports of foreign financial accounts (FBAR) to include virtual currency as a type of reportable account under 31 CFR 1010.350.
The IRS continues to focus on cryptocurrency. See the following resources:
- Virtual Currencies, here.
- Frequently Asked Questions on Virtual Currency Transactions, here.
- IRS 2020 draft 1040 puts crypto question front and center (Accounting Today 8/24/20), here.
Added 1/16/21 5:30 pm:
A good article on developments on Virtual Currency in this context is James Creech, FinCEN Moves To Include Convertible Virtual Currency On FBAR Form (Procedurally Taxing Blog 1/15/21), here.
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