IRS Provides A “Solution” for Streamlined and OVDP When Taxpayer has No SSN

The Offshore Voluntary Disclosure Program and the Streamlined Filing Compliance Procedures are procedures set up by the IRS to help Americans with overseas accounts and assets achieve tax compliance.  The streamlined program allows for taxpayers to certify that their tax noncompliance occurred as a result of “non-willful” conduct.  
 The streamlined procedures explicitly state that all tax returns submitted under the program require a TIN, namely the SSN for US persons:


“All tax returns submitted under the streamlined procedures must have a valid Taxpayer Identification Number (TIN).  For U.S. citizens, resident aliens, and certain other individuals, the proper TIN is a valid Social Security Number (SSN).  For individuals who are not eligible for an SSN, an Individual Taxpayer Identification Number (ITIN) is a valid TIN.  Tax returns submitted without a valid SSN or ITIN will not be processed under the streamlined procedures.”
I have had conversations with IRS representatives at the OVDP Hotline on this matter and explained to them the problems faced by many Americans who, soon after birth, moved overseas with their parents and never returned to the US.  Most of them had no idea of their US tax filing obligations since they have been living their lives hundreds of thousands of miles away from America, have been educated abroad, are working abroad and are likely paying taxes to the governments in their country of residence.
Based on my conversations, the IRS has finally devised a means through which one can submit tax returns into either the OVDP or Streamlined programs despite having yet received a SSN.  So long as the US taxpayer has begun the process of applying for a SSN, he can submit to the IRS the required Streamlined (or OVDP) paperwork along with a passport copy and a cover letter explaining that the SSN has been applied for.   The IRS will issue a special IRS number for that taxpayer to use on all correspondence with the IRS. Once the SSN is obtained, the taxpayer must advise the IRS.  This is a fairly painless method to become tax compliant even though one is without a SSN.
 http://blogs.angloinfo.com/us-tax/2014/09/29/2608/