Form 90-22.1 reporting obligation: foreign life insurance policies



Repeat, for the record, of a statement posted on another list/group:

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The position of the Department of the Treasury is that premium
payments for insurance policies with cash surrender value or other
investment features constitute "deposits" within the meaning of Form
90-22.1. Therefore, if a life insurance policy is a "whole life" or
other type of policy with investment value, then it is an "other
financial account" subject to reporting.

A U.S. person must file Form 90-22.1 for years where the aggregate
cash surrender value (not face amount) of any foreign life
insurance policy held by the U.S. person, together with any other
foreign bank accounts so held, exceeds $10,000.

It is a foreign account if the policy is located abroad. It is not the
nationality of the policy issuer that determines the location of the
account. It is the actual location of the account itself. Thus
simply because a foreign company issues a policy does not mean that it
is located in a foreign country.

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