Re: Where is firepay located?
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FWIW, you need to disclose all foreign assets, if your combined balance at any time during the year exceeds $10,000.
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It's not foreign assets, it's foreign financial accounts.
The IRS publication on this topic gives a definition and examples of financial accounts. In some cases reasonable people might disagree on whether a particular asset is a financial account, but clearly many foreign assets are not financial accounts.
However, FirePay is definitely located outside the U.S. and IMO is obviously a financial account based on the I.R.S. definition.
Standard disclaimer IANAL.
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