Will the IRS claim FBAR penalties to first dual citizen filers?

http://www.irs.gov/newsroom/article/0,,id=250788,00.html

6.  Possible penalties for failure to file FBAR


Taxpayer had a legitimate purpose for maintaining the foreign accounts, there were no indications of efforts taken to intentionally conceal the reporting of income or assets, and no tax was due.  Taxpayer’s explanation for why he failed to timely file an FBAR appears reasonable in view of the facts and circumstances of the case.  Since the IRS determined that the FBAR violation was due to reasonable cause, no FBAR penalty will be asserted.




However


http://www.taxpayeradvocate.irs.gov/userfiles/file/2011_ARC_MSP%2012.pdf


page 227:



While the IRS-released fact sheet is helpful, it has not been vetted like changes to the IRM or items published in the Internal Revenue Bulletin, and the IRS would be the first to point out that taxpayers generally cannot rely on fact sheets and press releases. 


What else do I need to know?


http://renounceuscitizenship.wordpress.com/2011/12/18/update-on-the-irs-fs-for-u-s-citizens-and-dual-citizens-living-outside-the-united-states-no-additional-relief-for-canadians/#more-714


Ms. Sereti is the chief architect and is in charge of the Offshore Voluntary Disclosure Initiative (OVDI).

• Penalty abatement for Canadian residents participating in the OVDI is available only if the taxpayer “opts out” of the program and successfully argues that he had “reasonable cause” for failing to file the returns.

• The IRS is aware of the problems caused by including registered retirement savings plans (RRSPs) in the OVDI penalty computation.

• The IRS is on the lookout for taxpayers who attempt to bring their unfiled returns current by using “quiet disclosure” and those who attempt to resolve their filing obligations in this way will face harsh penalties.”

As an american by birth living in a foreign country, how many documents do i have file to the IRS?

http://www.crevelingandcreveling.com/blog-list/104-for-american-expats-us-tax-form-checklist.html

1. Form 8938 (New)—Statement of Foreign Financial Assets. This is a new tax form that is required for some U.S. citizens who are foreign residents. U.S. expats need to file Form 8938 for tax year 2011 if their filing status is Single, Head of Household, or Married Filing Separately, and they had more than $200,000 in aggregate foreign assets on the last day of the year or $300,000 at any time during the year. For U.S. expats who file Married Filing Jointly, the threshold limits for filing are higher―you need to file Form 8938 if you have aggregate foreign assets of $400,000 on the last day of the year or $600,000 at any time during the year. For more information on Form 8938, see "Some Good News for U.S. Expats on FATCA and Form 8938."
2. Form 8621—Information Return for Passive Foreign Investment Company (PFIC). If you own shares in a Passive Foreign Investment Company (such as a foreign-domiciled mutual fund, offshore investment scheme, or resident country tax-deferred fund), you're required to file Form 8621 for each PFIC in years that you have a realized gain or distribution for that fund. However, it can also be advantageous to you to file this form annually. That way you can elect the method that you'd like used to calculate tax on your PFIC income. If instead you wait to file Form 8621 until you have realized gains or distributions, you'll have to accept the IRS's punitive default method of calculating tax on your investment return.
3. Form 2555—Foreign Earned Income. If you qualify, you may be able to exclude foreign earned (salary) income of up to $92,900 for 2011, as well as potentially exclude or deduct housing costs using this form.
4. Form 1116—Foreign Tax Credit. If you've paid foreign taxes on foreign income (either from your salary or investments) and you haven't otherwise excluded the income from your U.S. taxes, you may be able to take a credit against any U.S. taxes owed by filing this form.
5. Form 5471—Information Return of U.S. Person with Respect to Certain Foreign Corporations. If you're a shareholder of a Controlled Foreign Corporation (CDC), you must file this form. A foreign corporation is generally classified as a CDC if you own 10% of the shares or control 10% of the voting rights. American expats who own foreign registered businesses or significant stakes in restaurants, bars, or other companies may need to file this form.
6. Form 926—Return of a U.S. Transferor of Property to a Foreign Corporation.Generally, you'll be required to file this form in the year you transfer cash, assets, or property (tangible or intangible) to a foreign corporation. U.S. citizens either just setting up and providing initial capital to a foreign business or injecting fresh capital/new assets to an existing business may need to file this form.
7. Form 8865—Information Return of U.S. Persons with Respect to Certain Foreign Partnerships. If you're a partner in a foreign partnership with five or fewer U.S. partners who each own 10% or more interest and in aggregate have more than 50% of the partnership, you may need to file this form to report income and transactions between you and the partnership.
8. Form 3520—Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts. This form is used to report transactions you may have with foreign trusts, as well as if you receive large gifts from foreign persons (greater than USD 100,000), or corporations or partnerships (greater than USD 14,375 for 2011).
9. Form 3520A—Information Return of Foreign Trust with a U.S. Owner. If you own a foreign trust you need to file this form to provide information about the trust, its U.S. beneficiaries, and anyone who's treated as an owner of any portion of the trust.
10. Form TD F 90-22.1 Report of Foreign Bank and Financial Accounts (FBAR). If you own or have authority over a foreign financial account, including a bank account, brokerage account, mutual fund, unit trust, or other types of financial accounts, and the aggregate value of all foreign financial accounts is over USD 10,000 at any time during year, you're required to report the account each year to the Department of the Treasury. Please note that this form is still required even with the introduction of Form 8938 described above.

if i have never filed us taxes, how many years should i file?

http://www.irs.gov/newsroom/article/0,,id=250788,00.html

1.  U.S. income tax return filing requirement


Generally, you only need to file returns going back six years.