Note: “ij” is a regular on Townsend’s blog. He is, from what I gathered, originally from China (I think), spent some time in Canada, when he opened up an RRSP account, and then moved to the United States. He entered the 2009 OVDP and has been very worried that an RRSP in Canada would be hit with a 20% fine. To this day, the IRS has not given guidance on RRSPs. If IJ is correct, and RRSPs will not be subject to OVDP fines, this sets a kind of precedent for all registered retirement accounts in the world, or so it could be argued, under the Equal Protection Clause.
From Just Me:
Just saw this here, and thought some Canadians might be interested. Can’t vouch for it….