Participation in the Streamlined Filing Compliance Procedures after previously submitting to the Offshore Voluntary Disclosure Program (OVDP) is generally not allowed if the OVDP submission was complete and accepted by the IRS. The OVDP was designed for taxpayers who might have willfully failed to report foreign financial assets and pay all tax due in connection with those assets. It offered a way to come into compliance while potentially avoiding criminal prosecution and paying predetermined penalties. Once a taxpayer has resolved their case under the OVDP, they have essentially closed that chapter of their tax compliance history with the IRS under the terms of that program.
It's important to note that the determination of willfulness versus non-willfulness is a critical and complex issue in deciding eligibility for the Streamlined Filing Compliance Procedures. Taxpayers should carefully assess their situation given the potential for significant penalties and legal implications; professional guidance is crucial in navigating these matters.