Individuals must report annually on foreign financial accounts if balances exceed a threshold amount. The question raised is whether these balances include cryptocurrencies. The Financial Crimes Enforcement Network may change the rules to specifically include these digital currencies. But instructions to FinCEN Form 114 for 2020, which is due April 15, 2021 (with an automatic 6-month extension) make it clear that cryptocurrency is not factored into balances as yet (https://www.fincen.gov/sites/default/files/shared/FBAR%20Line%20Item%20Filing%20Instructions.pdf).
A written determination issued to a taxpayer by the IRS that interprets and applies the tax laws to the taxpayer’s specific set of facts. A letter ruling advises the taxpayer regarding the tax treatment that can be expected from the IRS in the circumstances specified by the ruling. It may not be used or cited as precedent by another taxpayer.