IRS Updates Procedures for Voluntary Disclosures

IRS Updates Voluntary Disclosure Practice The IRS issued a memorandum on November 29, 2018 that updates the process for domestic and offshore voluntary disclosures after the 2014 offshore voluntary disclosure program ended on September 28, 2018. The OVDP program began in 2014 as a modified version of the 2012 OVDP program, which itself followed voluntary disclosure programs offered in 2011 and 2009. What is IRS Voluntary Disclosure? Voluntary disclosure is a long-standing practice of the IRS to provide taxpayers with criminal exposure a means to come into compliance with the law and potentially avoid criminal prosecution. The traditional IRS Voluntary Disclosure Practice is outlined in I.R.M. 9.5.11.9.  The IRS memorandum updates this IRM section. The traditional voluntary disclosure process did not have much of a framework. These new procedures provide more certainty, much like the now-discontinued OVDP program. Steps for Making a Voluntary Disclosure Under the…

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