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Streamlined Filing Compliance Procedures: IRS Foreign and Domestic Amnesty Programs

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, July 26, 2022

Recorded event now available

or call 1-800-926-7926

This webinar will guide international tax advisers through streamlined compliance programs offered by the IRS to bring taxpayers up to date on their tax and foreign reporting obligations. Our authoritative panel will explain eligibility requirements and required documentation as well as offer advice to facilitate acceptance and resolution of past noncompliance.


For taxpayers behind on their income tax and information return filing obligations, the IRS offers streamlined compliance programs. The requirements are stringent, but the benefits include substantial penalty relief and peace of mind for taxpayers seeking amnesty. The Streamlined Foreign Offshore Procedures (SFOP) provide relief for nonresidents, including abatement of penalties.

The Streamlined Domestic Offshore Procedures (SDOP) for residents include a five percent Title 26 miscellaneous offshore penalty. Both programs require that taxpayers certify that their noncompliance was nonwillful. Prior tax returns and additional foreign reports, including Forms 8938, 3520, 5471, and the FBAR, are among the voluminous required submissions for both the SFOP and SDOP.

Some taxpayers chose to file and expatriate. The transition tax under Section 965 must be calculated and paid. Practitioners can provide a valuable service by assisting noncompliant multinational taxpayers with the streamlined compliance procedures. Understanding how to avoid common errors and expedite the acceptance of these agreements is critical.

Listen as our panel of international tax experts guides you through SFOP and SDOP to help taxpayers become compliant.



  1. Streamlined Foreign Offshore Procedures (SFOP)
  2. Streamlined Domestic Offshore Procedures (SDOP)
  3. Required submissions
    1. Income tax returns
    2. Information returns
    3. Certification statements
  4. Expatriation and Section 965 transition tax
  5. Handling an audit
  6. Avoiding common errors
  7. Alternatives to SFOP and SDOP


The panel will cover these and other critical issues:

  • What is considered nonwillful noncompliance under the streamlined compliance programs?
  • How the five percent Title 26 penalty is calculated for the SDOP
  • Which taxpayers are eligible for the SFOP?
  • What common errors should practitioners avoid when filing for relief under the streamlined compliance programs?


Castellanos, Alicea
Alicea Castellanos, CPA, TEP, N.P.

CEO & Founder
Global Taxes

Ms. Castellanos is the CEO and Founder of Global Taxes LLC. She provides personalized U.S. tax advisory and compliance...  |  Read More

Warshaw, Melvin
Melvin A. Warshaw, JD, LLM
International Tax and Estate Planning Lawyer

Mr. Warshaw has nearly 40 years of experience as a U. S. estate planning and tax lawyer. He currently represents U. S....  |  Read More

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CPE credit is not available on downloads.