I [Z] am the sole shareholder/officer of a small C corp.[Y] The
corporate owner [X] of 2 foreign financial accounts (at the same
financial institution) granted Y a Limited POA to manage the
investments in those 2 accounts. I can re-allocate the funds between
those 2 accounts. But I have no signature or other authority to
withdrew any funds/securities from those foreign accounts. I have no
financial interest in those accounts.

Reading the FAQ of the FBAR, I don't believe I need to file the TD F
90-22.1. However, given the substantial penalty for non-filing, I
thought I would file it just to be safe.

I tried calling 800.800.2877 x2 twice; each time I get the voice mail
and no one calls me back. I also sent an email to
FBARQUESTIONS[at]irs.gov; and have not received a response. So I thought
I would tried here.

My question on the form are as follows:

1. Who would be the filer -- Y Or Z?

a. If Y is the filer, is there a box on the F1120 that I need
to check -- like the box on Schedule B for individuals?

2. Since neither Y nor Z owns the accounts, do you leave item 14 not
checked at all -- since checking "No" would implied that the filer
owns the accounts singly?

3. Item 20 would be zero -- since I would be marking item 26b [no
financial interest in the account]?

TIA

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