@user17636035548
First thank you for your post with all the answers to my questions.
Second, please accept my apologies for delayed response.
Part of the delay is my struggle with unclear directions from the form 8938 instructions. While I recognize that despite Under model 1/2 IGA between US and UK there is no requirement for the UK pension admin / trust to report the holding to the US-IRS/ Treasury. However, this does not abate the requirement for the beneficiary/ pensioner from reporting under FATCA regs.
The question then ( and because of the distributed/ contorted information gathering on the form ) is how to report this "pension " account. If one looks at IRC section 1471-5 for definitions used in FATCA regs, I am more inclined to report a pension account like an annuity i.e. under custodial account . This is in contrast to your information of reporting as a trust ( see definition in the above ref 26.USC 1471-5... ).
Since the whole idea of FATCA is to detect/ avoid money laundering through "specified foreign financial assets/ accounts", all one is required to do is generally report the holding but generally under headings as defined under section ref'd above. So my view is to report the pension account as a custodial account. The pension fund is holding your monies ( your contribution & that of your employer ) and investing and growing for future "annuity" type of payment to you as beneficiary.
This would mean that line 20 -- Custodial; line 21 -- is your account identification at the pension fund admin
26a -- Name of the fund admin; 26b is blank or the IGA model 1 or 2 ( as the case may be )
I do not agree that this should be reported as a trust where you own a specific share etc.
That is my take on this. Is there more I can do for you ?
