I attended a U.S. tax seminar yesterday and where the following link was given out on what does not “constitute” reasonable cause for not filing your tax returns. If you use any of these reasons you can be assessed a 5000.00 penalty.

http://www.irs.gov/irb/2007-14_IRB/ar20.html

I can say that after coming out of that meeting yesterday I can only conclude that, unless one took a vow of poverty, it will be well nigh impossible to get out of this mess without incurring a lot of pain. According to the presenter the IRS is coming out sometime soon with guidelines on how dual citizens can become compliant.