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Coming Out of the Dark: Streamlined Filing Procedures

Wednesday, July 1, 2026 · 2:00 p.m.  |  Eastern Time (US & Canada) (GMT -4:00)

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Matt Eddleman walks through the Streamlined Filing Compliance Procedures, covering the Streamlined Foreign Offshore Procedures (SFOP) and Streamlined Domestic Offshore Procedures (SDOP). He'll examine what the IRS looks for in a valid certification, what distinguishes non-willful from willful conduct, and why a false or conclusory certification can create more exposure than the original non-compliance.
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Presenter
1780501925-a78be6ea6bfac47c
Matt Eddleman
EA
Matt Eddleman brings more than two decades of professional experience in tax controversy, accounting, financial planning, and small business management to Frost Law's Tax Compliance team.
About
Learning Level: Basic

Many U.S. taxpayers with foreign financial accounts and unreported offshore income find themselves out of compliance, not through deliberate concealment, but through a lack of awareness of their obligations. For those taxpayers, the IRS Streamlined Filing Compliance Procedures offer a structured, penalty-reduced path back into compliance. But the program is not without complexity, and the stakes of getting it wrong are significant.

Level: Intermediate
Field of Study: Taxes
Delivery Method: Group Internet-Based
Prerequisites: Basic familiarity with U.S. individual income tax compliance; prior exposure to FBAR and foreign account reporting concepts helpful but not required
Agenda
  • Overview of the Streamlined Filing Compliance Procedures and their origin
  • Identify eligibility, penalty structure, and track selection of SFOP vs. SDOP
  • Discuss the non-willfulness standard: definition, examples, and certification requirements
  • Evaluate step-by-step filing mechanics for both tracks
  • Determine audit protection, program limitations, and disqualifying conditions
  • Discuss special situations such as inherited accounts, accidental Americans, joint accounts, and how to avoid common submission errors
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