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IRS Updated Voluntary Disclosure Practice

On November 20, 2018, the IRS issued a Memorandum addressing the process for all voluntary disclosures (both domestic and foreign) following the close of the Offshore Voluntary Disclosure Program on September 28, 2018.  In March 2019, the IRS released new Form 14457, Voluntary Disclosure Practice Preclearance Request and Application.  The updated guidance and new form are important for taxpayers seeking to participate in the IRS voluntary disclosure program. The objective of the voluntary disclosure practice is to provide taxpayers concerned that their conduct is willful or fraudulent, and that may rise to the level of tax and tax-related criminal acts, with a means to come into compliance with the law and potentially avoid criminal prosecution. Taxpayers considering making a voluntary disclosure should contact competent tax counsel, who can explain updated procedures and help evaluate the options.