Realized I had a PFIC while living abroad years ago. I cannot find the tax statement. Banks report US holdings (FATCA), can IRS tell me what I owe?

From your phrasing I'm assuming you're a US citizen who was living outside the US.

Several things come to mind to suggest to discuss with your tax adviser (US-licensed CPA/EA/Attorney).

• Lack of form 8621 (used to report PFIC) may leave the return open and suspend the statute of limitation, that is true. But depending on your specific situation, may not be all the years that remain open. See the TC decision on this topic in Toso v. Commissioner.

• Depending on the extent of the holding (or some other factors), form 8621 may not have been required for the years you received no distributions or income with regards to the PFIC (See 26 CFR 1.1298-1(c)).

• Depending on how and when you reported the transaction and the income (loss) resulting from it, there may be no tax liability.

• Penalties are a function of tax liability unless fraud is suspected. There are no penalties for not filing the form 8621, but PFIC tax regime may lead to more taxes than regular capital gains tax that you probably used to calculate the tax on the income (if there was any).

• In any case, there's no obligation to amend your return if you believed it to be full and correct when you filed it.

• Correcting this yourself may (in fact, most certainly will) cost you more than the penalties the IRS will charge if and when they ever audit you.

Depending on the extent of the potential exposure, your tax professional will recommend a course of action.

Re FATCA - it doesn't require the foreign financial institutions to report a detailed account of your holdings. You can see what is being reported by checking the IRS form 8966.