I know that the back taxes exemption applies if the IRS initiates the levy. If you can wait 5 years you can roll it over into a Roth and withdrawl the CONTRIBUTIONS without a penalty tax. This isn't the type of finance I usually do, I may be wrong about this.
Not particularly relevant but...13 years ago I saw a large IRA fund taken care of and the owner even used his US passport for the accounts they went into. This was before that modern US tactic of trying to force foreign banks to report US citizen accounts. The account had grown a lot due to warrents and stocks at .001 par ect, instead of compensation, going into the account. So this was to avoid tax coming out not penalties. Anyway the money was extracted by putting it into a placement that was secured by foreign bonds. They defaulted, the placement was used to cover and the IRA account was 0. It didn't work, sort of, the US IRS only started sending letters and people 6 years later, the inheritance triggered their interest more than the losses in the self directed account. But he was dead, his wife and children aren't US citizens and didn't cooperate, the money was in lots places. Other things happened, but for the most part they stopped asking for information after about 4 months.