Thank you for the additional information. It helps.
When filling out Form 8938 (Foreign Financial Asset Disclosure), and where you own shares of a non-public foreign company, we would recommend reporting this asset using a method similar to that shown in the screen-capture image found directly underneath this text; simply click the icon to open and view.
This demonstrates how a US taxpayer can complete the data entry for Form 8938, in a manner consistent with the rules, and disclose their ownership of shares in a (hypothetical) foreign corporation. Of course, your own data entry will look somewhat different, and will be customized to your particular situation; but, the basic process should still be essentially the same.
Please keep in mind as well that there are no actual taxes due with Form 8938, as it is purely a disclosure document. Therefore, there is no incentive to do anything here other than be completely honest, and value the foreign stock appropriately. Essentially, the IRS just wants to know about the nature, and amounts, of foreign assets held by US taxpayers -- which is why this disclosure is necessary under the law.
Thank you for asking this important question.
