Thanks @AmyC! We did find this document from the IRS today, which says:
"But, you don’t need to report foreign financial accounts that are:
- Correspondent/Nostro accounts,
- Owned by a governmental entity,
- Owned by an international financial institution,
- Maintained on a United States military banking facility,
- Held in an individual retirement account (IRA) you own or are beneficiary of,
- Held in a retirement plan of which you’re a participant or beneficiary, or
- Part of a trust of which you’re a beneficiary, if a U.S. person (trust, trustee of the trust or agent of the trust) files an FBAR reporting these accounts."
The CPF is owned by a governmental entity. The insurance policies are owned by an international financial institution. So I think that is where the accountant's answer was coming from. My wife's only other account is a bank account with less than U.S. $2k.
(Side note: that webpage is under Small Businesses & Self-employed, but it says in the content of the page that these requirements apply to individuals, too.)
TurboTax is a little bit confusing here. I guess on "Tell Us about Any Foreign Bank Accounts", I should still check the same boxes. But on "Value of All Your Foreign Accounts", should I say no (it's not over $10k)? That screen should have been more specific.
