prabakaran
New member
My question is if Wise accounts are FBAR reportable, and if so, how to report them. Here is a brief list of points that I think contribute to my conclusion:
Edit: not related to Wise but I think--if my conclusions are correct--that accounts like PayPay, LinePAY, Rakuten Pay, Merpay, etc would also be in scope for FBAR.
Edit 2: 31 U.S. Code § 5312 (a) (2) (j) is probably not the most applicable definition for "financial agency" in this code, replaced with 31 CFR § 1010.100.
- Wise Japan is "Wise Payments Japan KK, which is registered as a Type 2 Funds Transfer Service Provider"
- A Wise JPY account does not have any identifying account number
- Opening other currency "jars" (as they call them) shows you Wise's c/o accounts that they use to move money around
- https://www.irs.gov/businesses/smal...t-of-foreign-bank-and-financial-accounts-fbar says "you don’t need to report foreign financial accounts that are Correspondent/Nostro accounts"
- 31 CFR § 1010.350 (c) (1) requires you to report accounts with entities that are "engaged in the business of banking" and to also report (defined 31 CFR § 1010.350 (c) (3) ) any “other financial account” that is "an account with a person that is in the business of accepting deposits as a financial agency"
- 31 CFR § 1010.100 (ff) defines (through parts (v) -> (t) (3) ) foreign financial agencies to include "money service businesses" that "deal in foreign exchange" or are "money transmitters" or "supply prepaid financial services."
- 資金決済に関する法律 defines the Type 2 Funds Transfer Service as "この章において「第二種資金移動業」とは、資金移動業のうち、少額として政令で定める額以下の資金の移動に係る為替取引のみを業として営むこと（第三種資金移動業を除く。"
- Funds Transfer Services (1) accept deposits and (2) are financial agencies under US code above
- From a layman's perspective you can keep and spend balances from Wise's jars similarly to a regular finance services institution account
- Wise issues Wise debit cards
- You do not need to report the currency jars in wise, as say, the GBP jar is a nostro account of Wise's
- You should report your Wise account and maximum balance, using your debit card or wise membership number as your account number
Edit: not related to Wise but I think--if my conclusions are correct--that accounts like PayPay, LinePAY, Rakuten Pay, Merpay, etc would also be in scope for FBAR.
Edit 2: 31 U.S. Code § 5312 (a) (2) (j) is probably not the most applicable definition for "financial agency" in this code, replaced with 31 CFR § 1010.100.