@lixiang based on your response and example ( thank you -- XieXie )
(a) my reading of 31CFR.1010.350.(c)(3), these accounts do fall under the reporting regs for foreign accounts -- for both FBAR and FATCA.
(b) Since the reporting person is a US person, has signature / operational authority over his/her portion of the pooled account ( one multi-person account that has investment/deposit in multiple subaccounts), he/she comes un der reporting requirements of FBAR and FATCA.
(c) For both FBAR and FATCA reporting the US person needs to report his/her participating amounts --- the fact that others may report using the same account number / institution is not material ( IMO) because what one is attesting to is the fact of having financial ( liquid or semiliquid ) interest abroad, even if the foreign financial entity reporting includes the whole pooled amount with a list of participants ( i.e. not reporting the value of each individual participant holding in the pool ). It may be somewhat fuzzy reporting but here the onus is on the US person holding a share of the pool.
(d) This also means that the US person must be recognizing the earnings from such pooled accounts whether distributed or retained.
Does this make sense ?
Is there more I can do for you ?
