Are Genentech employee's RSU/S-SARs in the mother company, Roche AG (a swiss company) foreign holding subject to FinCEN 114 reporting?
I have a client who is an employee of Genentech USA Inc. He gets stock options (RSU and S-SAR) in Roche AG, a swiss company. As far a we understand the rights are held in Switzerland. Equatex US, inc acts as agent and interactive Brokers LLC acts as executing broker for all transactions. Each is broker-dealer registered with SEC, a member of FINRA and of the SIPC. My question is... are these rights subject to FinCEN 114 reporting.