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Category: Tax Crimes

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 

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 […]


I Received a Letter from IRS Criminal Investigation (IRS CI). What Now?

IRS Criminal Investigation (IRS CI) conducts inquiries targeting a wide range of both tax-related and non-tax-related offenses—and these inquiries can present substantial risks for high-asset and high-income taxpayers. This includes not only the risk of substantial liability for back taxes, interest and fines, but also the risk of federal incarceration. […]