Up to now the FBAR amnesty processing dance has been:
Step 1. Go to your local IRS Criminal Investigations office. Get cleared there.
Step 2. Get your file sent to the IRS Philadelphia unit, where most things international seem to happen. This is where your taxes, penalties, and interest would be calculated.
I know it will shock you, but apparently the people in Philly are bogged down in amnesty paperwork. This has led to a change in the FBAR amnesty procedure.
One of the attorneys in our office was in San Francisco for a session with the IRS and Franchise Tax Board on Friday, and they announced that they’ll be changing the processing. They’ll be shipping the Step 2 work out to local field offices for processing.
This is consistent with rumors I heard from Supervising Special Agents and from sitting in on conference calls with the IRS people from Washington DC. It makes sense. You have to figure that the people in Philadelphia have been inundated. Better to share the wealth with the local IRS folks.