Am I Non-Willful Under The OVDP Streamlined Procedures ?

FEEL LUCKY? The streamlined procedures do not limit the civil penalties otherwise associated with the reporting of U.S. source income. The streamlined procedures do not provide protection from a possible criminal prosecution referral. Taxpayers pursuing the streamlined procedures are required to certify under penalties of perjury that their conduct was "non-willful." [While] the vast majority of taxpayers likely believe their inadvertence was "non-willful"...[t]he issue is whether the IRS will a...