@Min Zhao whereas I agree with the comments from my colleagues @marctu and @KanchanM , the focus here has only addressed the 8938 reporting requirements i.e. these would come under FATCA regulations ( as trusts/ entities). However, because these are un-regulated insurance companies ( may be regulated under Foreign/ local tax laws), they would generally be classed as PFICs ( Foreign Passive Investment Companies). If this is true then there may be also mark-to-market recognition requirements -- of any residual value. This is just for awareness at this stage but may indeed become a tax event.
