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“This week the IRS released statistics on the number of returns it received in 2010 from US citizens with foreign trusts. In all of Canada only 324 returns were filed that report ownership in a non-US trust, which likely means hundreds of thousands of US citizens residing in Canada had not filed the appropriate returns.  This is important for two reasons: first, the penalties for not filing are draconian (but waivable); and second, last week the US Government Accountability Office (GAO) issued a report that encouraged IRS to pursue those taxpayers who file late returns using a technique known as ‘quiet disclosure.’”

http://www.moodystax.com/irs-says-hundreds-of-thousands-of-us-citizens-are-not-reporting-canadian-trusts/