Fbar and 8891 back filing

[taxidiot]

I am a Cdn citizen and US resident since August of 1993. I have an RRSP in Canada as well as bank accounts amounting to more than 10,000. None of these accounts is interest bearing - no income to report. Two issues

RRSP - FBAr and 8891 - do i really have to amend back to 1993? Let's say I file amendments back to 2005. What happens to the account growth between 1993 and 2005 when I withdraw my RRSP in retirement.

FBAR - Again...back to 1993? I can't imagine my bank still has records for maximum account balance etc. Is it true that it is unecessary to amend schedule b for every year and just file past fbars instead.

Advice please. I am embarassed that I had no idea about these reporting requirements and want to come into compliance.

[nelsona]

As a US resident , only the growth prior to arrival in US is exempt from US tax. Since you did not declare any of the income on your 1040, this does not change. You will elect to defer taxation, and when you begin taking RRSP/RRIF withdrawls, your pre-US growth will be tax-free. If you cannot determine your pre-US growth, the entire distribution will be taxable.

You need only go back six years for 8891 and FBAR.

[tsanaha]

good to know that US can always tax on unknown growth by taxing on the whole growth. otherwise, it does seem to me that late election taxpayers would have taken advantage of Uncle Sam.

[nelsona]

Indeed. In the instance where you need to provide gross and net income, the burden of proof as to how certain gross income is excluded in the net income becomes the taxpayers.

Since arrival in US value is the only way to establish any basis, and reporting net income the only way to affect the basis, failing to report changes nothing to one's basis, thus the one cannot increase the non-taxable basis by being 'forgetful'.

[tsanaha]

what in my mind is not that it will be fair to the gov, it also gives IRS a way not to punish and impose penalty on late f8891 election and forgot real growth after becoming US person.

for the taxpayers this is far much better deal than any sort penalty -- particulary like FBAR.