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Author: Lawrence Brown

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 […]


IRS Begins Audits of Corporate Jet Usage

On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to conduct “dozens of audits on business aircraft involving personal use” throughout the year. Citing the IRS’ additional funding under the Inflation Reduction Act, the News Release quotes IRS Commissioner Danney Werfel as stating: “With expanded resources, […]