Client was a UK citizen before moving to the US several years. (this was long before he was my client however). 

Client definitely doesn't have 10% ownership so it looking like he will fall under the PFIC/Form 8621. The Distribution itself was a LTIP Distribution. The stock was obtained when he worked for the company in the past. 

With regards to the FBAR/8939 filings. My understanding is that he is in the clear for FBAR filing because the stock itself isn't in an actual account. While he would have to report the value of a foreign asset on 8938 since its under the reporting threshold he would be all set right?