In an update to her December 2012 report, the Taxpayer Advocate has noted that the IRS still has not provided reasonable options for “benign actors”, or taxpayers who inadvertently violated the rules for reporting foreign accounts.  The Taxpayer Advocate noted that the IRS revocation of pre-clearance letters had damaged IRS credibility and might lead to decreased voluntary compliance.  Furthermore, the IRS has not followed the Taxpayer Advocate’s previous recommendations that the IRS send notices to educate those with foreign accounts about filing requirements and has not addressed the duplicative and burdensome requirement to report certain accounts on Form 8938 and the FBAR.