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

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 8

In 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 general

• The role of accountant vs. an attorney in amnesty program disclosures with a specific discussion related to the preparation of the Non-Willful Statement

• The timeline of involvement for an attorney in an amnesty program disclosure

• The key differences of Willful vs. Non-Willful behavior including the associated civil penalties

• A 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) submission

Learn more about Austin C. Carlson:

• Visit the News & Resources page on Gray Reed’s website: https://www.grayreed.com/NewsResources
• View Austin C. Carlson’s profile on Gray Reed’s website: https://www.grayreed.com/Our-People/Austin-C-Carlson

• Connect 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/@GrayReedLaw

• Follow 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

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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/2beZfOpwfBlBgWHlNelAOf

Connect 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