If passive foreign investment company (PFIC) issues are involved, the amended tax returns submitted as part of the final OVDP packet will need to be modified to reflect the statutory PFIC computations (rather than the specialized mark-to-market computations within the OVDP).

FORBES: FATCA Blues? Opt Out Of IRS Offshore Program

Second, the suspension of the 3-year statute of limitations is expanded to (1) annual reports required to be filed by a Passive Foreign Investment Company (PFIC), (2) the election of a PFIC shareholder to have the PFIC treated as a qualifying electing fund and (3) reports of foreign financial assets (a new form to be attached to and made a part of a tax return).

FORBES: THE GOOD OLD DAYS PRE-FACTA