Account number one is the simple one, which is exactly why Hipster almost missed it. Soon after landing, he walked into a local bank, showed his passport, and opened a checking account to get paid, pay rent, and stop bleeding wire fees. Over the year, freelance income came in, rent went out, and the balance bounced between the equivalent of $2,000 and $14,000.
To him, it was just checking. To the FBAR, it's a "financial interest": under 31 CFR § 1010.350(e)(1), being the owner of record or holder of legal title is enough. No income required. No money ever sent home required. Ownership alone does it.
The test isn't his December 31 balance. It's whether his foreign accounts combined exceeded $10,000 at any time during the year, converted to dollars at the Treasury's year-end exchange rate. One big invoice took his balance to the equivalent of $14,000 for a few days before rent cleared. That's enough, even though most days he was far below.
And "account" means more than checking. 31 CFR § 1010.350(c) lists bank accounts, securities and brokerage accounts, and other financial accounts such as mutual funds and cash-value insurance, if the institution is outside the US. A foreign brokerage account he opens later counts the same way.
