Simple 3520a Situation

Technical topics regarding tax preparation.
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Simple client in Brazil. A US person who contributes a portion of his wages to his retirement Brazilian plan. His employer does not contribute - just him. Brazil defers his Brazilian income tax on his contributions - like a 401k with no matching.

Is it correct to summarize:

1) I must include the deferred income as part of his foreign earned compensation on his US tax return
2) This part of his income is not eligible to be excluded with the FEIE or creditable toward the FTC
3) We have a yearly form 3520a filing requirement due MARCH 15 (without an extension or statement)
4) We probably have a 8621 requirement (PFIC)
5) Growth (appreciation) and interest/dividends in this account is all taxable EACH year on his US return as it grows.
6) Distributions are not taxable to the US, but now form 3520 is required in any year in which there is a distribution.
7) Foreign tax paid to Brazil on distributions are not creditable under the FTC
8) This account might need to be included on FBAR and 8938, as applicable, based on the aggregate value thresholds.

Am I all good?
 

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