Tax
Nov. 5, 2016
IRS expands definition of 'non-willful' conduct
At a recent tax conference, an IRS official provided an expansive definition of non-willful conduct, stating that even conduct considered "gross negligence" could qualify as non-willful. By Mitchell B. Dubick and Joshua P. Katz
Ever since the IRS first rolled out the Streamlined Filing Compliance Procedures (SFCP) in 2014, one of the biggest challenges for attorneys and other tax professionals has been advising taxpayers whether their actions meet the non-willful conduct standard required to utilize SFCP - rather than the more extensive and expensive Offshore Voluntary Disclosure Program (OVDP) - when disclosing foreign financia...
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