According to an article published December 2, 2011 in The Globe and Mail, a Canadian periodical, the IRS might be lenient on US citizens (and green card holders) living in Canada who didn’t disclose their “offshore” accounts by filing Form TDF 90-22.1. (This form is sometimes known as the “FBAR” form, based on an abbreviation for “foreign bank account reporting.”) David Jacobson, the US Ambassador to Canada, was quoted as saying that “if … you don’t owe taxes to the US, and you file your return[s] and they show you don’t owe taxes, there aren’t going to be any penalties for having filed late.” He reportedly also said the IRS position would be published within “weeks.” Presumably he means there will be no penalty for late filed FBAR forms so long as late filed Forms 1040 demonstrate that no tax is due.
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