Taxpayers seeking to qualify for the reduced penalties of the IRS's streamlined offshore voluntary disclosure program (OVDP) need to certify the facts provided when asserting that their conduct was not willful.
The regular OVDP does not require that taxpayers certify that their failure to disclose offshore accounts was not willful. The streamlined program requires a non-willfulness certification and does not provide audit protection.
To certify, you must provide a written statement, under penalty of perjury, for all overseas activities and assets. The statement must detail specific reasons for your failure to report income, pay tax, and submit required information. This certification will be reviewed by IRS examiners and if they find it questionable, the taxpayer may be subject to criminal investigation.
Questions? Contact your Berdon advisor or Saul Brenner at 212.331.7630 firstname.lastname@example.org.