A. Background
Since 2012, US citizens1 living in Canada (and
elsewhere outside the US) have had two options to address income
tax non-compliance issues: the Offshore Voluntary Disclosure
Program ("OVDP") and the Streamlined
filing procedure ("Streamlined"). The
more comprehensive OVDP program offers criminal amnesty after
pre-clearance, extensive disclosures, and a mandatory penalty
payment. Streamlined presents a less onerous path of fewer filings
and reduced (or eliminated) penalty. Originally, Streamlined was
available only to nonresident taxpayers as defined by the terms of
the program.2 On June 18, 2014, the IRS announced modifications to the streamlined filing
procedure.3 One modification was the establishment of
the "Streamlined Domestic Offshore Procedures." This
program opens the Streamlined filing procedures to US resident
taxpayers, and was intended for US resident taxpayers who had
failed to disclose offshore assets, but whose failure to disclose
had
