The IRS has recently expanded the eligibility requirements for streamlined OVDP. If you are a U.S. taxpayer with offshore accounts, the streamlined procedures could be beneficial for you, with some penalties waived.
To qualify for the streamlined procedures, you must certify that your conduct (not having reported foreign accounts) was “non-willful.” The IRS defines “non-willful” as negligent, inadvertent or due to a misunderstanding of the law.
Is this an opportunity to come into compliance in an organized, timely manner or, as is asked in this Forbes column, is it the government’s attempt “to entice unsuspecting taxpayers into placing their head onto the FBAR chopping block?”