An American citizen, foreign resident, holds stock of an American company through a foreign brokerage house in his country of residence.
Does he have to include the value of this stock in his FBAR and 8938 when reporting the brokerage account? Are the dividends paid through the brokerage considered foreign or U.S. income for income tax purposes? The latter question arises because in one case the foreign income tax can be used as an offset to the US income tax on the holding; in the second case the US tax can be used as an offset to the foreign tax.