On October 8, 2014, the IRS issued FAQs clarifying its amnesty
programs for non-compliant taxpayers who want to catch-up on their
U.S. tax filing obligations.1 These FAQs address the
recently amended streamlined filing compliance procedures, offshore
voluntary disclosure program (OVDP), and delinquent information
return and FBAR submission procedures.2 The FAQs are not
relatively enlightening, except for the FAQ on the nonresident streamlined procedures
(dubbed the "Streamlined Foreign Offshore Procedures" by
the IRS). After briefly summarizing some relevant general rules
regarding streamlined, this blog will address the consequences of
that FAQ for snowbirds who have not filed during the three-year
period for which tax returns must be submitted under streamlined
and, according to the IRS, spend too much time in the United
States. Ultimately, these snowbirds are ineligible for streamlined
and must find an alternative way to catch-up with their U.S. tax
filing
