Statue of limitations; didn't know about Cdn Mutual funds

[MGeorge]

Hi All,

I'm a US citizen living in Canada. I've recently learned from reading this forum, and other websites that most foreign (Canadian) mutual funds are considered PFICs for US tax purposes.

I also recently filed form 3520A and 3520 for my TFSA which contains Cdn mutual funds - but the balance is less than $1500. I figured I would just file forms 8621 for the 2012 tax year since the Mark to market income would have been a loss for the previous 2 years.

The scary part is, I had a non-registered account (with Cdn mutual funds)that had a much larger balance from years 2005-2009. A CPA did my US returns from 2005-2010 and he simply listed the dividend, interest and capital gain income from the non-registered account. The details of the account are in my FBAR. What is statute of limitations on any taxes owed if this is reasessed and the mutual funds are treated as PFICs?

Thanks.

[primo]

The statute of limitations is 3 years from when the return is filed. If there are problems, then they can go back further.