Tag Archive for Streamlined OVDP

Streamlined OVDP’s “Nonwillful Narrative” Requirement

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Taxpayers using either the Streamlined Foreign Offshore Procedures or the Streamlined Domestic Offshore Procedures, will be required to certify, that the failure to report all income, pay all tax and submit all required information returns, including FBARs (FinCEN Form 114, previously Form TD F 90-22,1) was due to Non-Willful Conduct.

The IRS’s OVDP Streamlined Procedures Forms require taxpayers to provide a narrative statement of facts, explaining their failure to disclose their offshore assets, or the IRS will consider the applications incomplete and the taxpayer won’t get Streamline Relief. The IRS Streamlined Filing Compliance Procedures website provides:

“Failure to submit this statement, or submission of an incomplete or otherwise Read more

So What Does “Non-Willful” Really Mean Under The Streamlined OVDP – Take 2?

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We originally posted on Thursday, September 18, 2014, “So What Does “Non-Willful” Really Mean Under The Streamlined OVDP?” where we discussed that it appears that whatever Non-Willful means outside of the OVDP streamline program; it is certainly being applied differently in evaluating a Taxpayer’s ability to transition from the OVDP program into this new 2014 streamline program.

We also discussed 2 news reports, both verifying that taxpayers who are currently in the OVDP program are having very little success in proving “non-willfulness” during their requests for transition into the new 2014 streamline procedure.

We then provided a pure guess, in attempt to explain the IRS’ almost like a blanket denial Read more

Changes To the Streamlined Version of OVDP To Be Announced Soon?

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According to the BNA the IRS will soon announce several changes to the streamlined version of the Offshore Voluntary Disclosure Program, but won’t change the policies behind eligibility for the program, two agency officials said September 20, 2014.

For domestic participants the IRS will consider only the taxpayer’s personal financial interests in determining eligibility, not accounts for which taxpayers only have signature authority.

The agency will make it clear that domestic participants will have to include, in the penalty base, foreign assets that they may have already reported on a Form 5471 or a Form 3520.

These comments were made at the fall meeting of the American Bar Association in Read more