Please note the following comment by Michael J. Miller:
3. Re: collection in Canada, I’m not sure what would possess a person to sign a closing agreement with the IRS if s/he did not intend to pay, so I’m not sure when it would be relevant. Having said that, if you signed a closing agreement providing for a 20% or 25% (or other) miscellaneous penalty, ostensibly under Title 26, then in my view it would be reasonable for the US to ask (and for Canada to agree) to treat it as a tax penalty.
If you ask me, our government has done a lot to assure Canadians and residents of Canada protection from FBAR penalties. But to enter an OVDI program and agree to penalties voluntarily is perhaps something that the Canadian government won’t or can’t protect you from. Please do not enter an OVDI program without taking into consider the possibility that the government of Canada will not protect you from the penalties. Credit goes to RenounceUScitizenship for pointing this possible problem. Thanks.