IRS Office of Chief Counsel attorney Daniel Price had some astute observations at the October 30 panel at the University of San Diego School of Law-Procopio International Tax Law Institute annual conference. For specific coverage by tax journalist Amanda Athanasiou of TaxAnalysts, in their Worldwide Tax Daily – IRS Addresses Questions About OVDP and Streamlined Filing
Specifically, Mr. Price said that “Practitioners know what tax fraud is, practitioners know what willful conduct is — the government doesn’t need to provide a negative definition in this context.”
The panelists spent a significant time on the streamlined filing compliance program and how it should be more efficient for taxpayers and the government. As reported in the TaxAnalysts article, Mr. Price “said the Service’s goal is to direct willful individuals with true criminal liability to OVDP and non-willful individuals to the streamlined program.”
See, IRS and Practitioner Comments on the Streamlined NonWillful Certification from the Federal Tax Crimes Blog for further comments and observations.