Indeed, there’s been no direct information from the IRS on whether taxpayers who invest in the digital tokens need to fill out Form 8938, which gets attached to their 1040 each year.
The American Institute of Certified Public Accountants has written to the IRS, asking the agency for further guidance on foreign reporting requirements.
Both the IRS and the Treasury Department did not respond to CNBC requests for clarification.
When it comes to the FBAR, Ozelli said recent case law found that foreign online gambling accounts did come with such reporting requirements, suggesting that cryptocurrency exchanges do as well.
“If you’re using foreign exchanges, it’s going to qualify as a foreign reportable account for FBAR,” Ozelli said.
And many cryptocurrency investors, she added, will find themselves in this situation. “A lot of the transactions still take place on foreign cryptocurrency exchanges,” she said.
More from Personal Finance:
Protect your bank accounts from rising debit card fraud.
The Bank of Mom and Dad is open for a quarter of working millennials.
Putting bitcoin in your IRA can sink your retirement.
Despite the ambiguity about the foreign reporting requirements, most tax professionals suggest erring on the side of caution.
“There is no set answer, but it never hurts to report,” said Daniel Morris, an accountant with expertise in digital currencies.
It’s risky not to, he said: “8938 is the only tax form that if you fail to file, and it’s deemed that you should have filed, it’s a potential felony.”