New IRS procedures for tax compliance

[Mach7]

As of Sept 01, there are new procedures for citizens abroad to become tax compliant.

http://www.irs.gov/newsroom/article/0,, ... 31,00.html

If you go to this link and click on the 'new procedure' its all there.

My question is with the paragraph dealing with the Canadian RRSP election.

A lot of us have just back filed 8891s with no PLR attached. As outlined below they seem to want something similar to the PLR...(or at least an explanation as to why the election was late in filing).

Does anyone think this new procedure with respect to 8891 explanations will come back to haunt the ones who filed 8891s (as outlined above in the backfile)....or can one assume that the IRS has accepted these and have moved 'on'?

Here is an excerpt from the new procedure:


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.

[tsanaha]

I don't think they will haunt those who back file f8891/FBAR quietly --- the worst would be asking you to make a formal request of late election which has been done already in the form.

It does make sense to add more work load on IRS themselves.

This new procedure is part of OVDI program for those who have other non-compliance issue. This is to separate offshore assets from in lieu penalty base.