Segal, Cohen & Landis, P.C.
Come Into Compliance Without Criminal Prosecution Risk
IRS tax attorneys — Beverly Hills, CA. National representation.
Streamlined procedures are for eligible individual taxpayers, including estates of individuals, who certify that the relevant failures were non-willful. An IRS civil examination for any tax year, or an IRS criminal investigation, makes a taxpayer ineligible. The domestic track requires previously filed returns for the relevant three years and generally a 5% miscellaneous offshore penalty. Qualifying foreign-track submissions receive specified penalty relief. Tax and interest remain payable, and neither track guarantees immunity from audit or prosecution.
How We Help
Our Approach to Streamlined Filing Compliance Program
Program Eligibility Analysis
Streamlined procedures are for eligible individual taxpayers, including estates of individuals, who certify that the relevant failures were non-willful. An IRS civil examination for any tax year, or an IRS criminal investigation, makes a taxpayer ineligible. The domestic track requires previously filed returns for the relevant three years and generally a 5% miscellaneous offshore penalty. Qualifying foreign-track submissions receive specified penalty relief. Tax and interest remain payable, and neither track guarantees immunity from audit or prosecution.
Amended Return Preparation
A streamlined submission generally covers the three most recent years whose return due dates, including applicable extensions, have passed, plus six years of required FBARs. The domestic track uses amended returns; qualifying foreign-track filers may submit original or amended returns. We prepare the applicable certification and supporting filings. The IRS does not acknowledge receipt under these procedures or issue a closing agreement; we retain delivery records and advise on future compliance.
Non-Willfulness Certification
The Form 14653 or Form 14654 non-willfulness certification is a signed statement explaining why your non-compliance was not willful. This document is legally consequential — we draft it with the precision of a legal brief.
Post-Disclosure Compliance
We advise on ongoing FBAR and foreign asset reporting obligations and how to maintain compliance going forward.
How It Works
The Resolution Process
Eligibility Assessment
We analyze your facts to determine whether Streamlined is appropriate or whether a more protective disclosure method is needed.
Document Gathering
We collect 6 years of foreign account statements, foreign income records, prior tax returns, and any prior IRS correspondence.
Return Preparation and FBAR Filing
A streamlined submission generally covers the three most recent years whose return due dates, including applicable extensions, have passed, plus six years of required FBARs. The domestic track uses amended returns; qualifying foreign-track filers may submit original or amended returns. We prepare the applicable certification and supporting filings. The IRS does not acknowledge receipt under these procedures or issue a closing agreement; we retain delivery records and advise on future compliance.
Post-Disclosure Compliance
A streamlined submission generally covers the three most recent years whose return due dates, including applicable extensions, have passed, plus six years of required FBARs. The domestic track uses amended returns; qualifying foreign-track filers may submit original or amended returns. We prepare the applicable certification and supporting filings. The IRS does not acknowledge receipt under these procedures or issue a closing agreement; we retain delivery records and advise on future compliance.
Ready to Resolve Your Tax Problem?
Our attorneys have helped thousands of clients resolve IRS matters. Your consultation is free and confidential.
Common Questions
Frequently Asked Questions
What is the difference between domestic and foreign Streamlined?+
The foreign track has a specific nonresidency test, not simply a foreign mailing address. U.S. citizens and lawful permanent residents generally must have had no U.S. abode and spent at least 330 full days outside the United States in at least one of the relevant three years. Other individuals use the substantial-presence test. Both spouses must satisfy the applicable nonresidency requirement for a joint submission.
What does non-willful mean?+
The IRS defines non-willful conduct as conduct that was due to negligence, inadvertence, mistake, or conduct that is the result of a good faith misunderstanding of the requirements of the law. Willful conduct disqualifies a taxpayer from Streamlined.
Further reading
Beverly Hills · Los Angeles · National
Segal, Cohen & Landis, P.C.
9100 Wilshire Boulevard, 601 East Tower, Beverly Hills, CA 90212
Free Confidential Consultation