The interesting part is that somebody submitted amended returns (1040X) with more than 5 informational returns (defined as Forms 3520, 3520-A, 5471, 5472, 8938, 926, or 8621) would be subject to additional scrutiny. At first look, that doesn’t seem to apply to “regular” streamlined submissions – i.e. 3 X 1040 & 6 X FBAR.
IRM 18.104.22.168.2.1 Adjusting Streamlined Filing Compliance Domestic Accounts
– (Streamlined Domestic Offshore – SDO)
3. LB&I will review the submissions for statute considerations. LB&I will complete the “AM Streamline Coversheet” and attach it to the package notating their statute recommendations regarding open statutes and statute extensions.
The IRS must determine if the certification is complete — a table checklist is provided in paragraph 7.
One thing they check for is an open examination. (See par. 8, table).
9. To complete adjustments on Form 1040X filed under the SDO:
6. After making the assessment, refer any case with 5 or more foreign information returns (Forms 3520, 3520-A, 5471, 5472, 8938, 926, or 8621) by e-mailing the CIS ID number to “*LB&I OVDP Compliance” with an explanation that the case is being forwarded due to 5 or more foreign information returns. Enter CIS notes indicating the case was referred to *LB&I OVDP Compliance “5 or more foreign income statements”
NOTE: The total of 5 forms is a combination of all years filed. For example submissions containing 3 Forms 5471 for 2011 and 3 Forms 5471 for 2012 would be referred since the total is 6. Submissions with a combination totaling less than 5 would not be referred.