Why should I act now?
The IRS have always been clear that the programme will have an end date. Recent anecdotal evidence tells us that the end date is coming in the near future. Such a move might come with immediate effect, although there is some precedent to suggest that the closure would be at the end of a period of notice.
The current submission process takes time with everything required by the IRS to be presented in a single package rather than instalments. If the closure of the programme is announced soon and is subject to a short notice period, it may be impossible to assemble the necessary submission before the programme closes.
Therefore, now is the ideal time for any US citizen with a delinquent tax profile who satisfies the ‘non-wilful’ test, to take advantage of the streamlined route back to compliance, before the opportunity disappears.