Learning Objectives

• Understand the major changes to the procedures since the IRS expanded them back on June 18, 2014
• An overview of the two types: streamlined foreign procedures and streamlined domestic procedures
• Understand the requirements for each and the subtleties that are so easy to overlook that they are a veritable trap for the unwary
• Understand the differences between each
• Understand the penalty structure under streamlined domestic — commonly referred to as the miscellaneous offshore penalty — including the types of assets that are included in the penalty base, how it captures a wider array of foreign assets than the miscellaneous penalty under OVDP, and how the penalty itself is calculated
• Answers to the most frequently asked questions regarding the streamlined procedures
• What does it mean for a taxpayer to certify that he/she was non-wilful in his failure to report his foreign assets for purposes of streamlined
• The elusiveness of non-willfulness
• Can your client successfully certify that his failure to disclose his foreign assets was truly non-willful? What are some things that are sure to attract the IRS’s attention
• Don’t try and fit a square peg into a round hole! Consequences of IRS rejecting a streamlined submission when your client is not an appropriate conduct and the parade of horribles that could follow
• IRS guidance for when it’s appropriate to make a “quiet disclosure.”
• Practical and sound advice regarding whether to go streamlined or go home.