The ruling stems from a specific inquiry by a taxpayer who, despite being unable to access their funds on a failed exchange, continued to receive partial bankruptcy distributions through a domestic account. The NTS determined that because the initial account was established with a foreign virtual asset service provider, the disclosure obligation remains in force regardless of the platform's solvency status or the user's lack of control over the assets.
Under South Korean regulations, residents and domestic corporations must report all foreign financial accounts if their combined balance exceeds 500 million won—approximately $350,000—at the end of any month during the calendar year. While the NTS has clarified that these accounts must be reported, the agency has yet to detail how taxpayers should value disputed or partially recoverable claims. Account holders are advised to maintain rigorous documentation, including bankruptcy notices and distribution records, to substantiate their filings against the balances displayed on defunct exchange interfaces.

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