I reside in Portugal. Do I have to declare my holdings of shares in a Gold fund created by Franklin Gold Miners which is a US company.

[RobertG · Accepted solution]

If it is an investment in an asset owned through a US brokerage or listed on a US exchange, then it would not be reportable

Foreign investments aren't considered a foreign financial asset (if owned through a U.S. brokerage or listed on a U.S. exchange) or money in a foreign branch of a U.S. bank. Form 8938 isn't required in these situations.

Specified Foreign Financial Assets Specified foreign financial assets include the following assets.

1. Financial accounts maintained by a foreign financial institution.

2. The following foreign financial assets if they are held for investment and not held in an account maintained by a financial institution.

a. Stock or securities issued by someone that is not a U.S. person (including stock or securities issued by a person organized under the laws of a U.S. possession).

b. Any interest in a foreign entity.

c. Any financial instrument or contract that has an issuer or counterparty that is not a U.S. person (including a financial contract issued by, or with a counterparty that is, a person organized under the laws of a U.S. possession).

2019 Instructions for Form 8938