QUESTION: Do UNALLOCATED metal assets held under the Perth Mint Certificate Program need to be reported on the IRS TDF90-22.1? I recently purchased your book "Reporting Foreign Financial Accounts" as well as the 2010 Update and searched both of them for an answer on this point, and have also searched your online Q&A looking for an answer, but I have not found one.
You have covered the ALLOCATED aspect of the Perth Mint Certificate Program and also the Perth Mint DEPOSITORY SERVICES (a completely different service, which operates like a private client bank account or stockbroking account, except with balances of precious metals in troy ounces---and IS reportable); however, the UNALLOCATED aspect of the Mint's Certificate Program appears to have not been addressed.
With the UNallocated Bullion program, one has title to precious metal deposited in an UNsegregated storage account, and is issued a Perth Mint Certificate. This is not a "managed fund"; it is simply a pool of unsegregated precious metal in which one purchases an interest.
The following description of the Certificate Program appears on the Perth Mint's website:
"With unallocated storage, also known as a metal account, clients purchase an interest in a pool of precious metal held by The Perth Mint. The Mint purchases an ounce of precious metal from the spot market for every unallocated ounce it sells to clients. Accordingly every unallocated ounce is 100% backed.
"The precious metal purchased by the Mint is recorded on its balance sheet as an asset and the unallocated amounts sold to clients are recorded as a liability.
"At purchase, clients only pay for the precious metal. There are no fabrication charges or storage fees, until clients elect to convert their unallocated into a specific coin or bar, which they can do at any time."
Since this question has not previously been specifically addressed or answered, I would really appreciate your view on the UNALLOCATED aspect of the Certificate Program in relation to the FBAR disclosure requirements.
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