Client was told she has sig authority over a company acct w/ 165M in it. They filled out 114 as it was needed (see part 4).
Since her ownership is zero, is form 8938 required?
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Per 8938 Instructions:
Who Must File
Unless an exception applies, you must file Form 8938 if you are a specified person (see Specified Person, later) that has an interest in specified foreign financial assets and the value of those assets is more than the applicable reporting threshold.
The instructions have detailed explanation/definition/examples on "specified person" and "an interest in specified foreign financial assets". Go over those and decide.
Without knowing all the facts, how could one give you the answer?
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