IRS FBAR Streamlined Procedures Revisited: Am I Non-Willful?

Am I "Non-Willful"? Taxpayers pursuing resolution of a foreign account issue within the Streamlined Procedures are required to certify, under penalties of perjury, that their conduct was “non-willful.” For purposes of the streamlined procedures, non-willful conduct is defined as conduct that is “due to negligence, inadvertence, or mistake or conduct that is the result of a good faith misunderstanding of the requirements of the law.” The issue at hand... is whether the IRS will agree. Feel lucky?