The above tweet references the original article.
Alison Bennett of Bloomberg BNA’s article “Questions surround Standard of Willful Path Conduct under Streamlined Version of OVDP” (9/17/14), summarizes some of her interviews with tax lawyers around the country concerning the Streamlined Filing Compliance Procedures announced by IRS on June 16, 2014.
I’ve questioned the usefulness of the Streamlined Process for U.S. persons in prior blog posts and my colleagues interviewed by Ms. Bennett have similar reservations. Some of the comments are summarized below, namely:
- The government may take a stricter view of non-willfulness for those trying to transition out of the OVDP into the Streamlined Process under the transitional rules also announced on June 16, 2014.
- One practitioner’s experience is that most transitional applications are being rejected by IRS.
- Apparently, as I’ve discussed in earlier posts there is no appeal of this IRS decision.
- The IRS seems to be interpreting non-willfulness using a stomach test: Did you know…
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