The Internal Revenue Service (IRS) has released new guidance for taxpayers applying for the streamlined offshore voluntary disclosure program in a new FAQ page on its website. Implemented in June 2014, the streamlined procedures are designed to lessen penalties for taxpayers who can certify that their failure to report an offshore bank account was non-willful. In the new guidelines, the IRS has clarified several important features of the program, including the residency requirements, some practical instructions for submission, and the potential lack of liability for taxpayers with signature authority on an offshore account. These new details should enable taxpayers and their representation to make more informed decisions on whether to apply to the streamlined procedures in the future. However, the IRS has not revealed new details on one of the key questions regarding the program: the specifics of how IRS agents assess the willfulness or nonwillfulness of a taxpayer in the holding of unreported offshore accounts. While the streamlined procedures will continue to offer a less punitive pathway to getting right with the IRS, it will indeed remain difficult to navigate successfully without the guidance of an experienced tax attorney. If you have an unreported offshore account, contact the international tax attorney at Daniel Rosefelt & Associates, LLC, Attorney & CPA now to discuss your legal options, including voluntary disclosure.