How Does the IRS Determine if Conduct is “Willful” or “Non-Willful”?
By Ani Galyan of MillarLaw A Professional Corporation On Monday, June 22, 2015
WILLFUL V. NON-WILLFUL CHECKLIST INTRODUCTION This Article is a guide for practitioners and taxpayers in deciding whether to apply for the streamline procedures of the IRS’s Offshore Voluntary Disclosure Program (“OVDP”). The streamline procedures require a certification of non-willfulness from the taxpayer. Non-willful conduct is defined as conduct that is due to negligence, inadvertence, or … Continue reading How Does the IRS Determine if Conduct is “Willful” or “Non-Willful”?