Traditional Voluntary Disclosure
National Offshore Voluntary Disclosure Program (OVDP) Lawyers
In addition to the 2009, 2011, and 2012 Offshore Voluntary Disclosure Programs, the IRS has also offered and continues to offer a voluntary disclosure program for tax matters unrelated to foreign income and asset issues. Under this program, taxpayers may be granted amnesty from criminal prosecution by disclosing information related to unreported domestic income, resulting in underreporting or underpayment of federal taxes. Though there is no guarantee of immunity from criminal prosecution, a voluntary disclosure can work to minimize the government’s interest in pursuing a prosecution.
In a traditional voluntary disclosure, the taxpayer communicates unreported information to IRS Criminal Investigation in a truthful, timely, and complete manner. If the IRS believes that the taxpayer is demonstrating a willingness to cooperate and pay delinquent taxes, interest, and penalties in full, amnesty from criminal prosecution can be granted through a closing agreement. The voluntary disclosure program is not available to taxpayers with illegal source income. In general, the IRS considers disclosures to be timely when the information is received prior to a formal examination or investigation by the IRS. However, at any time during the disclosure process, if the IRS discovers that the taxpayer has not given them complete information or if the IRS obtains additional, undisclosed information about the disclosing taxpayer from a third party, the negotiations can be terminated.
Foreign Bank Account Disclosure Attorney
Voluntary disclosure is not right for everyone. As a former Department of Justice, Tax Division trial attorney, Lawrence Brown understands the federal government’s procedures, policies, and priorities. The knowledgeable team of CPAs, attorneys, and former IRS agents at Brown, PC can discuss your case and help you determine the best strategy for minimizing your risk. Contact our team of tax professionals at 817-870-0025 or toll free at 888-870-0025 to schedule a highly confidential consultation.