US residents with UK pension from former job

[tax1111]

Client is US resident/citizen and used to work in UK and has a UK pension account.
Are the following questions what I should ask to decide what forms to file for him?
1. is it a employer pension or individual pension?
2. is the pension an employees’ trust (satisfy the following requirements)

Employee contributions must not exceed fifty percent
The individual is not a employee with high compensation and
The plan must not be discriminatory (as determined under Section 401(a)(26) or 410(b)).

If it is a employees' trust, then no need to file 3520, 3520A and 8621. But need to file 8938 and fbar.

Is such a conclusion correct?

Since the client already left UK, does it mean that he is not a highly compensated employee for determining if his pension is an employees' trust? even though his income used to be higher than the threshold? Or in other words, if a person left his UK employer, he is no longer a highly compensated employee no matter how high his salary with the UK employer?

Also, does US-UK treaty have any relief of filing requirement of 3520, 3520A, 8621 if the pension is not a employees' trust.

[Sara EA]

I think you're right.  If the value of the pension is determinable (e.g., there's $x in it and there will never be more), then FBAR is required.  If not determinable, like the client gets $x each year for life, then no FBAR.

[Catherine]

I thought the determinant was control. Can the client request/demand a full payout, or determine how the funds will be administered? Or do they just get money every year? If it's in an employer program and the client has benefits but no control, there is no reporting required.