Taxpayers confess their intent, but what about the IRS?

Streamlined procedures require taxpayers to certify their non-willful avoidance of paying taxes, but the IRS intent is yet to be proven. Jeffrey S. Freeman, J.D., LL.M The IRS offshore disclosure programs were created to bring those with unpaid taxes from their offshore accounts to rectify their errors. Intentional or not, the offshore voluntary disclosure programs (OVDP) still hit individuals with penalties ranging from 27.5-50%, but they are protected from further audit and criminal liability. The OVDP protects taxpayers from possible criminal charges stemming from tax evasion or concealing tax payment, filing false returns, and failing to file income tax returns. A recent addition to the offshore disclosure programs, streamlined procedures, allows individuals that can certify that their tax compliance was non-willful to pay a lesser penalty. As with any new program, many questions have been raised as individuals work with their legal counsel to determine if the streamlined procedures is truly an option for them. Non-willful To take advantage of the streamlined procedures you must certify that your conduct was "non-willful." For IRS purposes "non-willful" conduct is conduct that is due to negligence, inadvertence, or mistake or conduct that is the result of a good faith misunderstanding of the requirements [...]