The son-of-FBAR 8938 now finally has some instructions. A couple quick points that might be of interest to Americans living abroad:
- Filing jointly means you get double the limits before you need file.
- There are much higher limits for Americans that live abroad: the threshold is $200,000 of foreign assets on the last day of the year and no more than $400,000 during the time of the year.
- Accounts held by “US payer” are exempt, which includes foreign branches of a US financial institution. (Citi is the only US bank that I know of in Spain)
- Accounts maintained by dealers or traders in securities or commodities if all holdings are subject to mark-to-market accounting rules. Being considered a trader is very tough, and you pretty much have to a full-time daytrader in order to qualify (otherwise you are an investor, not a trader).