IRS Amnesty and The Streamlined Filing Compliance Procedures

  • Total presentation time: 60:00

The Internal Revenue Service announced major changes in its offshore voluntary compliance programs, providing new options to help both taxpayers residing overseas and those residing in the United States. These changes will provide thousands of people a new avenue to come into compliance with their U.S. tax obligations. The expanded streamlined procedures are intended for U.S. taxpayers whose failure to disclose their offshore assets are non willful.

This is an extremely important and valuable I.R.S. Program. It allows almost every American who has been afraid to step forward and disclose their foreign assets to the U.S. taxing authorities to do so with minimized penalties on unpaid taxes and unfiled information returns. Purpose of the streamlined procedures: The streamlined filing compliance procedures are available to taxpayers certifying that their failure to report foreign financial assets and pay all tax due in respect of those assets did not result from willful conduct on their part. The streamlined procedures are designed to provide to taxpayers in such situations:

  1. a streamlined procedure for filing amended or delinquent returns and
  2. terms for resolving their tax and penalty obligations. These procedures will be available for an indefinite period until otherwise announced. This means that just as the Internal Revenue Service has suddenly announced this highly beneficial “settlement tool”, the Internal Revenue Service can withdraw the program. Eligible taxpayers need to act quickly.

Veteran South Florida Tax Attorney Richard S. Lehman will explain:

The I.R.S. New Amnesty Program

  • Beginning taxable year 2012. The tax wake up call for Americans with unreported assets and/or income

The New IRS Streamlined Filing Compliance Procedures

  • The IRS Makes Changes To Offshore Bank And Foreign Asset Disclosure Programs
  • The eligibilty for the streamlined procedure
  • Quiet Disclosures, OVDP
  • The test for willfulness
  • The benefits of the streamlined procedure

Presentation Resources:

  • PRESENDATION SLIDES: Download as pdf
  • PRESENTATION SCRIPT: “I.R.S. Makes Changes To Offshore Bank And Foreign Asset Disclosure Programs” Read online


1. The Foreign Account Tax Compliance Act (FATCA): Americans now required to disclose all foreign financial assets Read article online

2. Foreign Financial Institutions: Reporting and Withholding United States Taxes Read article online

3. The Amnesty Program for Unreported Foreign Income Read article online

Bonus Materials:

United States Treasury Decision 9567: IRS Temporary Regulations on reporting of specified foreign financial assets.

Instructions for Form 8930: Statement of Specified Foreign Financial Assets.

The New Treaty and Annex: download pdf -31 pages includes:

  • Model Intergovernmental Agreement to Improve Tax Compliance and to Implement FATCA
  • ANNEX 1: Due diligence obligations for identifying and reporting on U.S. Reportable accounts and on payments to certain non participating financial institutions
  • ANNEX 2: Non-reporting [FATCA Partner] Financial Institutions and Products

IRS “Amnesty” Questions:

 Real Testimonials:

-Great course. Very Relevant and Timely. (LSchilling, GTN, Sr Manager)
-Great coverage on a difficult topic! (JLiao, IRS, Staff)
-Currently preparing a tax return via VDP, this was a very informative webinar. (ERomero, self-employed, Owner/Partner/Principal/President/CEO/Shareholder) -Excellent job for a hard subject (RBeninati, Toobrich Consulting Corp., Owner/Partner/Principal/President/CEO/Shareholder)
-Excellent, practical presentation of complex subject. Good job by Atty. Lehman (RGuarino, Guarino Tax Consultants, Owner/Partner/Principal/President/CEO/Shareholder) -Foreign net asset holdings and taxes – a presentation truly interesting and worthy of your investigation! (CJohnson, Charles R. Johnson, CPA, Staff or Senior)
-Good overview of subject matter & recent developments in allotted time. (MARCELLA MARRA, M MARRA CPA, Owner/Partner/Principal/President/CEO/Shareholder) -Good reference material (JMartin, John Martin, CPA, Owner/Partner/Principal/President/CEO/Shareholder)


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