Date: February 20th , 2026

Time: 1pmET | 12pm CT | 11am MT | 10am PT

Duration: 90 minutes

Course Overview:

As offshore enforcement remains a top priority for the IRS, international reporting compliance has become one of the most sensitive and high-risk areas of tax practice. For taxpayers who failed to report foreign income, accounts, or assets—but whose conduct was non-willful—the streamlined filing procedures offer a critical opportunity to correct past noncompliance in a structured, penalty-mitigated manner.This in-depth, practitioner-focused session provides a strategic and practical roadmap to navigating the streamlined program effectively and ethically.

Participants will gain a clear understanding of:

• The eligibility framework for both domestic and foreign streamlined submissions.
• The technical differences between program tracks.
• The documentation and disclosures required for a compliant filing.
• How to properly draft and support a credible non-willful certification statement.
• Common red flags that trigger scrutiny or audit exposure.
• The significant risks of quiet disclosures and informal corrections.

Beyond procedural mechanics, the session places streamlined filings within the broader international enforcement landscape, equipping practitioners to determine:

• When streamlined procedures are appropriate.
• When alternative disclosure programs may be necessary.
• When a client’s facts may elevate risk beyond streamlined eligibility.

Topics Covered:

•  Streamlined Eligibility & Submission Requirements.
• Domestic vs. foreign streamlined procedures.
• Residency and non-residency tests.
• Required amended returns and information forms.
• Penalty structures and risk exposure.
• Non-Willful Certification Standards.
• IRS definition of non-willfulness.
• Conduct that supports or undermines credibility.
• Drafting persuasive certification narratives.
• Practical examples and fact-pattern analysis.
• Quiet Disclosures & Alternative Compliance Options.
• Why quiet disclosures can be dangerous.
• Enforcement trends and audit risk.
• Comparing streamlined procedures to other voluntary disclosure pathways.

Learning Objectives:

• Explain eligibility criteria for IRS streamlined procedures.
• Prepare essential elements of a complete streamlined submission.
• Define non-willfulness using IRS standards and practical examples.
• Distinguish streamlined filings from quiet disclosures and other options.

Credits and Other information:

• Recommended CPE credit – 1.5
• Recommended field of study – Taxes
• Session Prerequisites and preparation: None
• Session learning level: Basic
• Location: Virtual/Online
• Delivery method: Group Internet Based
• Attendance Requirement:  Yes
• Session Duration: 90 minutes

Who Should Attend:

• CPA
• Enrolled Agents (EAs)
• Tax Professionals
• Attorneys
• Other Tax Preparers
• Finance professionals
• Financial planners

About Our Speaker

Michael DeBlis,JD,LLM,BA

Michael is a trial lawyer. He graduated Cum Laude from The Thomas M. Cooley Law School and Summa Cum Laude from the Thomas Jefferson School of Law with his Masters of Law in Taxation. Michael is known for his charismatic personality and his unyielding dedication to his clients.

Michael spent the first five years of his legal career as a public defender in the NJ Office of the Public Defender cutting his teeth on some of the most serious felony cases to pass through the state courts of New Jersey. He then joined his father’s law practice, DeBlis Law, expanding the practice into civil tax controversies and international tax compliance.

As a graduate of the National Criminal Defense College, Michael has trained under some of the best-known criminal defense attorneys in the country. That experience has taught him that justice for a person accused of a crime is only won through a full understanding of the client and the case.