The procedures announced in 2012 were available only to non-resident, non-filers. Among the changes made were the elimination of the following requirement that the taxpayer have $1,500 or less of unpaid tax per year and that filing out a risk questionnaire was required. The new rules require taxpayers to certify that previous failures to comply were due to non-willful conduct.

Under the disclosure program, all penalties will be waived for eligible U.S. taxpayers residing outside the United States, all penalties will be waived. Those eligible taxpayers living in the country need face only a miscellaneous offshore penalty equal to 5 percent of the foreign financial assets that gave rise to the tax compliance issue.