Navigating The Choppy Seas of The Streamlined Procedures

This course covers the streamlined procedures in exquisite detail since the IRS expanded the procedures back on June 18, 2014.

Please Note:   This course is eligible for IRS credit.  If you need credit reported to the IRS for this program, please download the IRS CE request form on the Materials Tab after you purchase the program and submit to leighanne.conroy@acpen.com.

Basic Course Information

*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

*Taxation