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That is a very interesting question. We researched it for you, and find that a foreign life insurance policy is reportable as a “foreign financial account” only if the insurance policy is owned by a U.S. person, and the policy has a cash surrender value. If there is no cash surrender value, then there is no reporting requirement. However, if there is a cash surrender value attached to the policy, then the dollar amount to report as a foreign financial asset would be just that (potential) cash surrender amount, and not the face value of the life insurance policy upon eventual payout.
Thank you for asking this, and we appreciate the opportunity to be of service.
A related question.
If the cash surrender value is below the $10000 threshold, should it still be reported as a foreign financial account in FBAR or should we not report anything at all as part of FBAR?
@sreenve If you have other foreign financial accounts that in aggregate exceed $10,000 on any one day in 2019, then you must report all of your foreign financial accounts no matter what balance they have.
If the foreign life insurance cash surrender value is less than $10,000 for all of 2019 and it is the only foreign financial account you have, then you do not need to report it.
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