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Category: Tax Controversy 

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 

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 […]


What to Know About IRS CI’s Voluntary Disclosure Practice

U.S. taxpayers that have failed to meet their filing and payment obligations have various options for resolving these “tax controversies” with the Internal Revenue Service (IRS). However, the specific options that are available in any particular case depend on the circumstances involved. For example, while IRS Criminal Investigation’s (IRS CI) […]


Am I going to jail if I made a tax mistake?

You’ve been a business owner for the last year. It is the first time you’ve run your own company, and fortunately, the business has done very well. You’re excited about the future and the revenue you earned. However, you’ve only done personal taxes before. You attempted to do your business […]

Tax Controversy