A Proposed Voluntary Disclosure Program for the California Franchise Tax Board

This paper provides a framework for discussing the implementation of a voluntary disclosure program for individuals and businesses with the California Franchise Tax Board.  The Internal Revenue Service has had a voluntary disclosure program for more than half a century, and it provides a mechanism for taxpayers to get back into compliance by making a truthful, timely and complete disclosure, showing a willingness to cooperate, and making good faith arrangements to pay in full the tax, interest and penalties. Yet unlike the Internal Revenue Service, the California Franchise Tax Board has no similar procedure for voluntary disclosure communications.