@BKKPilot , while I study the comment and the sources thereof , I show you the IRS position on this --->
Publication 4261
What you are arguing is that a person whom requests/ chooses to be treated as a "Resident for Tax Purposes " is not-necessarily as US Person ( and therefore subject to FBAR and FACA regs ). To me , how do you distinguish between a Resident for Tax purposes due to SPT / GreenCard vs. a Resident for Tax purposes by request . This a priori make no sense . Either you are a US person or you are not.
However, I will investigate the situation.
pk
