Certification of Non-Willfulness for Streamlined Filing

The eligibility requirements for expanded Streamline Filing were published on June 18th, 2014. There are two ways for a taxpayer to engage in Streamline Filing. First, if the taxpayer is engaged in the offshore voluntary disclosure program (OVDP) and has yet to complete the closing agreement or form 906, the taxpayer can request transitional treatment. If the taxpayer has yet to enter OVDP, the taxpayer can directly engage the streamlined filing process. Either way, to engage in streamlined filing compliance procedures (SFCP) the taxpayer will have to certify non-willfulness. The expanded streamline procedures have a more favorable penalty structure than OVDP, so if non-willfullness can be proved, this is the preferable option.

For more information about streamlined filing, what constitutes non-willfullness and how to engage in SFCP, download the article below by Mishkin Santa, LL.M, J.D, Director of International Advisory & Legal Services at Five Stone Tax.

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