CRA confirms that a new individual depository account exceeding $50,000 cannot be designated for FATCA exclusion once it falls below $50,000
ITA s. 264(1)(b), when read in conjunction with the (FATCA) InterGovernmental Agreement, effectively provides that a Canadian financial institution may designate a financial account to not be a U.S. reportable account for a calendar year if the account is a New Individual Account unless the account balance exceeds $50,000 at the end of “any” calendar year. CRA confirmed that this means that once the $50,000 threshold is exceeded at any year end, “it remains reportable regardless of its balance in subsequent years, and thus may no longer be designated pursuant to paragraph 264(1)(b).”
Neal Armstrong. Summary of 20 August 2018 External T.I. 2018-0759081E5 under s. 264(1)(b).