Alright so we are back in now we're heading into the land of streamlined walking procedures streamlined is not an offshore voluntary disclosure rather a procedure in which to disclose previously undisclosed foreign assets and income where you are non willful so our first form is form 14 653 certification by US persons residing outside of the US and let's talk about that a little bit so this is a form that the person is signing to say what are they certified basically what they are certifying and this is an item of some debate but what they're certifying is basically the amounts of tax that they owe and they're certifying their narrative their statement of facts on why these assets these accounts and the income wasn't declared previously and as part of the streamlined program taxpayers have to amend their tax returns for the past three years or for the streamline foreign offshore procedures many people residing outside the US didn't file their returns so they have to file original returns for the past three years all right so let's look at some of these the problems of this certification form then so let's start off with this first one something about statute of limitations yes when going through the program as I said you have to file either original or amended returns for the past three years now with original returns the IRS has no statute of limitations to assess additional tax so statute of limitations really doesn't come into play there but for people who are filing amended returns for the past three years there's a very narrow category in which taxpayers could be asked to provide amended returns that the IRS will never be able to process so for a person filing for example at 2,000 11 tax return and we're going to say well in today's date is October 16 2015 so for this fact pattern that's what we will zoom okay to Soviet Union we would have to assume for her to October 1500 prior so we're going to go back in time so really were 14 comes into play is the measuring time period before the streamlined program as it corresponds to tax returns for the streamline program you decide what are the past three years by taking the most recently past due date for filing your tax return whichever one is passed the most recently that's the most recent year in your three-year period and you go back three years from there okay so let's say somebody filed an extension for their 2014 tax return so we're after April fifteenth but they have until October 15th to file their 2014 tax return but normally they file their tax returns by April fifteenth every year many of our clients are in that situation so let's say we reach June of 2015 they filed an extension for their 2014 tax return now they're going to be filing their streamlined submission including tax returns for 2011 2012 and 2013 because the due date for 2014 hasn't passed because that's still not coming till October 15th correct that one's still timely if it's filed today so they're doing 11 12 and 13 well...
