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An Overview of IRS CI’s Voluntary Disclosure Practice

For high-income and high-net-worth U.S. taxpayers who are at risk of facing criminal prosecution due to willful tax law violations, making a voluntary disclosure to IRS Criminal Investigation (IRS CI) can facilitate a favorable resolution that avoids formal charges. But, making a voluntary disclosure presents its own risks—and it isn’t […]

Tax Controversy 

What is an “Attempt to Evade or Defeat Tax?”

Tax evasion is a serious federal crime. Individual taxpayers convicted of tax evasion can face up to a $100,000 fine and five years of federal imprisonment, while corporate entities can be fined up to $500,000. This raises an important question: What does it mean to “attempt to evade or defeat […]

Tax Evasion

VDP vs. Streamlined Filing Compliance: What U.S. Taxpayers with Offshore Assets Need to Know

The IRS’s Voluntary Disclosure Practice (VDP) and its Streamlined Filing Compliance Procedures both provide ways for high-income and high-net-worth taxpayers to proactively resolve issues related to the disclosure (or non-disclosure) of their offshore assets. But, the VPD and Streamlined Filing Compliance Procedures are very different—each being subject to its own […]

Offshore Accounts/International Tax Disputes

IRS Issues Updated FAQs on the Voluntary Disclosure Practice (VDP)

The Voluntary Disclosure Practice (VDP) provides an avenue for high-income and high-net-worth taxpayers to resolve significant federal tax controversies without facing criminal prosecution. Administered by IRS Criminal Investigation (IRS CI), the VDP is a long-standing program that allows eligible taxpayers to mitigate their exposure and settle with the IRS—provided that […]