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.”