Serbinski Accounting Firms

There is a difference between FBAR penalty and 3520 penalty because they are under different titles of US codes. FBAR penalty won't become a debt until the court judgement while 3520 penalty is under Revenue code, and the service can collect them as if they were tax due. Even if CRA won't collect it...

FBAR penalty is under title 31 US code. Even IRS can not collect FBAR penalty on US residents unless DOJ takes the case to the court for a judgement.

3520 penalty is under title 26, and IRS can collect the penalty -- I am not sure if CRA will collect them for IRS on Canadian residents (US expats).

Just found out, it is under title 26

http://codes.lp.findlaw.com/uscode/26/F/68/B/I/6677

is penalty on 3520 under title 26 or under title 31 (just like FBAR) ?

Thanks, I will do the convert, and I guess this must be done in person (i read a comment somewhere here awhile ago)

when RRSP can be converted to RRIF ? I mean at what age ?

Just found

http://www.irs.gov/newsroom/article/0,, ... 79,00.html

IRS also charges $2000 for PLR, according to Hogden I can't find the fee on IRS web.

Walsh, if you have not yet done with f8891, you should just follow nelsona's suggestion and file them now. if IRS does want to change the rules, they will have to explain what they did in the past. It is IRS's responsibility to keep its policy consistent and notify taxpayers in advance of any change.

from Cambridge Advanced Learner's Dictionary Problem 1. a situation, person or thing that needs attention and needs to be dealt with or solved. Sorry, English is not my native language, and I am only using the version for learners. Thanks for correcting me and forgive me for being ridiculous LOL

Nelsona,

I have a few friends with RRSP problem, and I do recommend them read this blog and follow your posts.

You are highly respected expert here. I am not disputing that and I wish I could have followed your post many years ago.

by the way, I am not making any recommendation here -- merely to alert the original poster the event of RRSP which I do care about, and it is indeed under review by IRS -- and hopefully they will come up a clear guideline

For the same token, PLR, and 9100 relief do exist as well - that is what these lawyers are trying to follow.

the fact IRS has no clear guideline on late f8891 filing, except posting some examples of PLR. i would not blame on these lawyers who simply follow the standard rule guided by IRS. However, in practice, this back filings are more like QD -- go under the radar of IRS -- and most time, they just do no...

http://hodgen.com/how-the-irs-can-make- ... -painless/


it seems IRS is reviewing RRSP problem