Noncompliant U.S. taxpayers should consult with their tax counsel to calculate their maximum tax, interest, and penalty exposure under the new procedures and determine whether filing a voluntary disclosure is appropriate. Although the new voluntary disclosure practice has upped the ante for all taxpayers it remains a very viable option for those with criminal exposure. Assessing this exposure is key before taking any action.
We expect that additional information regarding the new voluntary disclosure procedures will be forthcoming. The IRS plans to release revised forms and to update sections of the IRM to reflect these changes to the voluntary disclosure procedures.
Barbara T. Kaplan, a shareholder and co-chair of the Global Tax Practice at Greenberg Traurig, focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.
This article is presented for informational purposes only and it is not intended to be construed or used as general legal advice nor as a solicitation of any type.