Protecting Attorney-Client Privilege in IRS Streamlined Filing Compliance Submissions: The Role of Kovel Agreements
The IRS Streamlined Filing Compliance Procedures (which includes the Streamlined Domestic Offshore Procedures and the Streamlined Foreign Offshore Procedures) offer a critical path to compliance for taxpayers who failed to report foreign financial assets but whose conduct was non-willful. While these procedures provide relief from certain penalties, the decision to come forward is often accompanied […]