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When Is It Too Late to Submit a Voluntary Disclosure to the IRS?

The IRS’ Voluntary Disclosure Practice provides a pathway to avoid criminal prosecution when you have willfully violated federal law. But strict eligibility requirements apply—including strict timelines. Even if you don’t know you are no longer eligible, submitting a voluntary disclosure too late lets the IRS use it against you. Willfully […]

IRS

When Can Federal Tax Mistakes Lead to Criminal Charges?

Federal tax mistakes can lead to criminal charges in various circumstances. While federal prosecutors must prove a willful violation of the law to pursue criminal charges, they can use various forms of evidence to substantiate allegations of willfulness. This includes evidence of willful ignorance of the law. As a result, […]

Tax Fraud

IRS Continues to Aggressively Target PPP and ERC Fraud in 2026

The Internal Revenue Service (IRS) is continuing to aggressively target businesses suspected of Paycheck Protection Program (PPP) and Employee Retention Credit (ERC) fraud in 2026. While the PPP and ERC were pandemic-era programs, widespread fraud has resulted in ongoing enforcement—including criminal enforcement in many cases. Exposing fraud under the pandemic-era […]

IRS