By now, most American taxpayers are aware that many new laws have been put in place to ensure that they report all of their offshore income, assets, and bank accounts. Until recently, there was also a program that imposed serious penalties on Americans who had not reported foreign income or bank accounts. The IRS even had the authority to press criminal charges against those who failed to report their offshore income. This regime lasted for several years until the Internal Revenue Service decided to make it easier for taxpayers to report their foreign assets and earnings without facing harsh penalties. However, there is one caveat – if the IRS can prove that a taxpayer's conduct was willful and they were aware of their reporting obligations, the new regime does not apply to them. Now, let's examine the details of the new regime, which was introduced on June 18, 2014. The IRS created the streamlined filing compliance procedures, which offer new options for US taxpayers living in the United States and abroad to come into compliance with foreign reporting requirements at a reasonable cost. It is important to note that these streamlined procedures are not available for those who have willfully failed to report their offshore assets. Under the streamlined procedures, eligible US individual taxpayers both inside and outside the United States can file amended tax returns to report their offshore income and submit information returns related to offshore assets. To qualify for the streamlined program, taxpayers must certify that their conduct has not been willful. Those who have willfully failed to report their offshore income or pay taxes on it, including those currently under civil or criminal examination by the IRS, are not eligible for the streamlined procedures. Many taxpayers have previously made quiet disclosures, meaning they filed their US taxes and reported...