Every year, U.S. persons are required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (“FBAR”), if the total amount of their foreign accounts exceed $10,000. Under current regulations, reportable foreign accounts include bank accounts, securities accounts, and certain other specified financial accounts (e.g., insurance accounts with cash values). See 31 C.F.R. § 1010.350(c).
On New Year’s Eve, however, the Financial Crimes Enforcement Network (“FinCEN”) announced its intent to broaden the list of reportable accounts to include virtual currency. Specifically, FinCEN issued a notice that provides:
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