2025 Deep Dive into Non-Willful Statements for Streamlined Filings with Austin Carlson

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 8In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Austin C. Carlson, JD, CPA, Partner at Gray Reed. As a business lawyer and CPA, Austin brings a unique and rare set of skills and perspectives to every area of his practice, which includes corporate and tax counsel on M&A deals, complex corporate and tax planning for domestic and international transactions, foreign account and income disclosure and penalty abatement issues. Give this episode a listen to learn more about non-willful statements and their importance to the IRS’s Streamlined Filing Compliance Procedures.Tune in for these key takeaways:A brief history of the IRS Offshore Voluntary Disclosure Program (OVDP), Streamlined Filing Compliance Procedures (SFCP), and Amnesty Programs in generalThe role of accountant vs. an attorney in amnesty program disclosures with a specific discussion related to the preparation of the Non-Willful StatementThe timeline of involvement for an attorney in an amnesty program disclosureThe key differences of Willful vs. Non-Willful behavior including the associated civil penaltiesA comprehensive discussion of the best practices and contents required for the Non-Willful Statement required for a Streamlined Filing Compliance Procedures (SFCP)A discussion related to the IRS processing time, expected responses, follow ups post Streamlined Filing Compliance Procedures (SFCP) submissionLearn more about Austin C. Carlson:Visit the News & Resources page on Gray Reed’s website: https://www.grayreed.com/NewsResourcesView Austin C. Carlson’s profile on Gray Reed’s website: https://www.grayreed.com/Our-People/Austin-C-CarlsonConnect with Austin C. Carlson on LinkedIn: https://www.linkedin.com/in/austin-carlson-jd-cpa-63031029/Follow Gray Reed on LinkedIn: https://www.linkedin.com/company/grayreed/Visit Gray Reed’s YouTube Channel: https://www.youtube.com/@GrayReedLawFollow Gray Reed on Facebook: https://www.facebook.com/GrayReedLaw/Further Resources:SDOP FAQ 13: https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures-for-us-taxpayers-residing-in-the-united-states-frequently-asked-questions-and-answers***********************************About The Essential Tax Podcast:In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.Watch or listen to more episodes of The Essential Tax Podcast: YouTube: https://www.youtube.com/@TheWolfGroupPC Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944 Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOfConnect and learn more from your host, Mishkin Santa: Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa