The IRS’s voluntary disclosure practice provides taxpayers who have previously not complied with their tax and reporting obligations a pathway back to compliance. The IRS’s voluntary disclosure practice is available to taxpayers whose non-compliance was willful, fraudulent, or even criminal. Under the IRS’s voluntary disclosure practice, taxpayers can avoid criminal prosecution and minimize otherwise applicable civil penalties. 

Learning Objectives:

• Determine when is a voluntary disclosure appropriate


• Classify who is eligible to make a voluntary disclosure


• Outline the mechanics of applying for and completing the voluntary disclosure process


• Identify the penalty framework applicable under the current IRS voluntary disclosure practice