Backfilling 8891 + 1040x

[Atlaas02se]

"a statement requesting an extension of time to make an election to defer income tax and identifying the pertinent treaty position;
for relevant Canadian plans, a Form 8891 for each tax year and description of the type of plan covered by the submission; and
a statement describing:
the events that led to the failure to make the election,
the events that led to the discovery of the failure, and
if the taxpayer relied on a professional advisor, the nature of the advisor’s engagement and responsibilities."


Does anyone know the pertinent treaty position for an extension of time to make an election to defer income tax for 8891?
It appears one only needs to backfill 8891 +1040x for three years.

[nelsona]

where are you "quoting" from.

[tsanaha]

I think he is quoting from


http://www.irs.gov/businesses/small/int ... 74,00.html

QA 54

This is IRS new OVDP 2012

[Atlaas02se]

Here is the link where I got this.

http://www.irs.gov/businesses/small/int ... 72,00.html

[nelsona]

I would still be quiet disclosuring for now. No need for a statement.