itonewbie
Level 15

Procedurally, what you proposed would be correct.  As for the certification, it would not be sufficient for your client to "add that failures report financial and income earned in the past resulted from non-willful conduct".  Rather, it should be ascertained how the failure was not.

One of the most common oversight is how foreign pension contributions are not reported, at all or properly, on the returns, even with streamlined procedure.

---------------------------------------------------------------------------------
Still an AllStar
0 Cheers