Who Form 8854 Streamlined 2023-2024

Music. Since the IRS commenced a streamlined program in July of 2014, over a hundred thousand people have voluntarily reported undisclosed foreign income and assets, filed tax returns, and information returns. All under the streamlined domestic and streamlined foreign offshore programs. In the beginning, only tax attorneys made streamlined submissions because the failure to file F bars in underreporting is potentially a criminal tax matter. However, once they became popular, CPAs, enrolled agents, and even tax preparers started submitting them, even though their disclosures were not protected by the attorney-client privilege nor the attorney work product privileges. Many of the streamlined packages prepared by the least experienced professionals include hastily prepared narrative certification of the facts, insufficient disclosures, and inadequate information returns and tax returns. These are the streamlined submissions that are now being audited by the IRS. The IRS is interviewing the CPAs, enrolled agents, and tax preparers directly and asking these individuals questions about what was said during the taxpayers' conversations with them. The IRS is trying to prove the taxpayers' actual knowledge about filing requirements is not what was reported on the narrative certification of the facts that was prepared by their CPA, enrolled agent, and tax preparer. This creates an enormous conflict of interest. These professionals are put in a position to either lie, risking their own license and perjury charges, or selling their clients down the river during the audit. The IRS also is interviewing the taxpayers directly and questioning them about what their CPAs, enrolled agents, and tax preparers told them to write down, rather than the actual facts. The interviews of the CPAs, enrolled agents, and tax preparers, as well as the IRS interviews directly with the taxpayer, does not occur with tax attorneys. As we will advocate all of your rights, including...