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Worldwide Tax Daily Quotes Zhanna Ziering on IRS's Streamlined Program at 2015 ABA Midyear Meeting

February 3, 2015, Worldwide Tax Daily
During the American Bar Association's 2015 Midyear Meeting, Caplin & Drysdale's Zhanna A. Ziering commented on changes to the IRS's streamlined reporting programs. For the complete article, please visit Worldwide Tax Daily's website (subscription required).

Excerpt taken from the article "ABA Meeting: IRS Says No Letters of Intent Before Entering Streamlined Program" by Andrew Velarde for Worldwide Tax Daily.

The U.S. government doesn't plan to allow taxpayers who may be considering entrance into the IRS's streamlined program for previous failure to report foreign holdings to secure their position in advance with a letter of intent, an IRS official said January 30.


Zhanna A. Ziering of Caplin & Drysdale Chtd. argued that creating something like the offshore voluntary disclosure program's pre-clearance request for the streamlined program could encourage taxpayers to come forward by removing pressures that they would otherwise face before entering the program.


In August 2014 the IRS released a procedural update for the streamlined program, IRM, stating that streamlined domestic offshore cases with at least five foreign information returns are referred to the IRS Large Business and International Division. Ziering noted that based on the IRM, it appears that domestic filers received more scrutiny during processing. However, McDougal said the initial examination referred to in the IRM is more for completeness and coherence, labeling it a "sanity check."

McDougal also acknowledged that some taxpayers who lack Social Security numbers experience difficulty obtaining them in order to participate in the streamlined program; Ziering noted that the wait to obtain an SSN can be six to eight months. McDougal said the IRS is discussing the problem with the State Department and the Social Security Administration and urges taxpayers to be patient. He added that the IRS is hesitant to create a "processing nightmare by having hundreds or thousands of cases" with no SSNs.


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