1. Taxpayers must certify that conduct was not willful

2. IRS has not initiated a civil examination of taxpayer's returns for any taxable year

3. Taxpayers eligible to use streamlined procedures who have previously filed delinquent or amended returns must pay previous penalty assessments

4. Taxpayers who want to participate in the streamlined procedures need a valid Taxpayer Identification Number

5. Taxpayers who are concerned that their failure to report income, pay tax, and submit required information returns was due to willful conduct and who therefore seek assurance that they will not be subject to criminal liability and/or substantial monetary penalties should consider participating in the IRS Criminal Investigation Voluntary Disclosure Practice and should consult with their professional or legal advisers