Jennifer Best of the
IRS stated that the IRS has deliberately refrained from offering a lot of examples about what
constitutes willful failure to disclose offshore assets. Taxpayers
are only allowed to use the Internal Revenue Service's streamlined offshore
voluntary disclosure program when they have failed to report foreign income or
foreign financial accounts or assets, if they can certify that their failure to
do so was non-willful. Every
taxpayer has a unique set of circumstances, therefore, definition of the term of "Willful" was intentionally left broad.
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