As I've been living in the United States for the last few years, I'm a "US resident for tax purposes" and am required to file the FBAR (FinCEN Form 114) reporting the amount of money in my foreign accounts. I have a savings account in an Indian bank that has a few linked fixed deposit accounts, with the FD accounts reaching maturity from time to time, whereby the money transfers to my savings account temporarily, after which I open a new fixed deposit account with approximately the same amount of money.
For the past few years, I've been consolidating the savings account and linked FD accounts all into one entry for my FBAR FinCEN Form 114, so the "maximum account value" I report is the maximum value of the total across the accounts, rather than the sum of the maximum for each account separately. So far, I have not gotten into any trouble for reporting things this way.
If I were to report each account separately, then the total of the "maximum account value" values would be much higher than what I currently report, and that higher value would be misleading. For instance, when a FD matures and closes, the money moves to my savings account, and then I open a new FD. That money therefore contributes to the maximum for both the old FD and the new FD, as well as for the savings account. In other words, it gets triple-counted.
Therefore, I believe that my current way of reporting is more in line with the spirit of the requirement. However, I have not been able to find anything in the filing instructions that confirms this understanding, nor have I received any other online confirmation of this in the limited Googling I did on the issue.
I'd love to get people's thoughts on this.
This past question seems related, but I'm particularly interested in the question of linked accounts within the same bank.
