The non-willful certification is the sworn narrative on Form 14653 or 14654 in which a taxpayer explains how the failure to report foreign accounts happened and why it was not willful.
It must cover the source of the funds, what the taxpayer believed and why, how the error was discovered, and what was done to correct it. The IRS reads it for consistency with the returns and the account history.
A thin or inconsistent certification is the most common reason a streamlined submission is rejected, and a false one is perjury. Willful versus non-willful.
FBAR, FATCA, streamlined procedures, voluntary disclosure, and foreign trust and gift reporting.
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Definitions are general information, not legal advice, and may not reflect the most recent changes in law.
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