What is the difference between Streamlined Filing and Voluntary Disclosure?
Compare the non-willful Streamlined procedures with voluntary disclosure and understand why the willfulness analysis comes first.
Streamlined procedures are for taxpayers who can truthfully certify that their failure to report and pay was non-willful. Voluntary disclosure is a different path for taxpayers with potential willful conduct and possible criminal exposure. The correct procedure depends on the full history, notices, assets, returns, and advice—not on the size of the account alone.