Whether a taxpayer is considered a resident of the United States is determined under rules specific to the streamlined procedures.Under the procedures, taxpayers residing in the United States are subject to a 5% miscellaneous offshore penalty, and taxpayers residing outside the United States are not subject to the penalty. The streamlined procedures are available only to taxpayers whose failure to report assets and income and file required information returns was due to nonwillful conduct.
Streamlined filing compliance procedures, introduced in 2012 for individuals residing outside the United States and in 2014 revised and expanded to also apply to taxpayers inside the United States, offer a potentially easier and less expensive alternative to the Offshore Voluntary Disclosure Program (OVDP) for qualifying taxpayers who wish to disclose unreported foreign assets and income and file related delinquent information returns.
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