This is a Moodys Gartner analysis of how the new Streamlined Program may present problems for Canadian snowbirds. Timely advice given the new cross-border shared day count (which should be in effect but I understand delayed).
This blog is the first in a planned two-part series that analyzes the changes to the IRS voluntary disclosure programs, and is limited to analyzing the amended streamlined program. Part two of this blog will analyze the amended OVDP program and the procedures for delinquent FBAR or information return submissions.
In summary, the recently amended IRS voluntary disclosure programs are positive for most taxpayers. Yet, significant uncertainty remains, particularly for Canadian snowbirds, which forces them to use the new 2014 OVDP if they wish to voluntarily disclose and, thus, provides a disincentive for them to disclose.