Recently, the IRS updated its Frequently Asked Questions and Answers page for the Streamlined Procedures to include a new section on amending Streamlined submissions. Since the inception of the Streamlined amnesty program, there has been some uncertainty as to how taxpayers should proceed if they realize, after the fact, that they have made a mistake on a Streamlined submission.
Is acceptance of a streamlined application automatic for those residing in Canada?
The primary criteria for acceptance into the Streamlined Foreign Offshore Procedure (“SFOP”) is that the reason for the non-compliance was due to non-willful conduct and that you meet a non-residency test.
Non-willful conduct requires you to certify on IRS Form 14653. Non-willful conduct is conduct that is due to negligence, inadvertence, or mistake or conduct that is the result of a good faith misunderstanding of the requirements of the law.
The non-residency requirement is generally met if in any one of the 3 past due years, you Read More
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