IRS recently revised the Foreign and Domestic certification forms for the Streamlined Procedures (Form 14653, here, and Form 14654, here) . Among other changes there is now a “Paid Preparer Section” for the preparer of the Certification as well as a tick box to indicate whether or not the filer permits the IRS to speak with that individual. A detailed description of the facts that the IRS deems important to include in the Streamlined statement is provided and clearly emphasizes that the taxpayer provide specific reasons for his tax noncompliance and that he tell the complete story. All this tells me that the IRS is looking more deeply at Streamlined filers. The longer the time drags on before compliance is achieved, the more the IRS will be questioning if the taxpayer really was “non-willful”.
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