Checked October 1, 2026: The IRS describes current VDP requirements separately from its proposed revision announced December 22, 2025. A proposal does not establish operative eligibility or deadlines until finalized and placed into effect. VDP addresses willful noncompliance; nonwillful errors have other potential correction routes. Preclearance does not guarantee preliminary acceptance, and disclosure does not automatically provide criminal immunity.
The IRS current Voluntary Disclosure Practice requires truthful, timely and complete disclosure of willful noncompliance using Form 14457. The separate revision announced December 22, 2025 remains described by current IRS guidance as proposed; a proposal must not be presented as an implemented rule.
Key Updates to the Voluntary Disclosure Practice
- Mandatory Admission of Willfulness
Taxpayers are now required to explicitly acknowledge that their prior tax noncompliance was willful. This admission is a critical component of the application process and serves to distinguish deliberate tax evasion from unintentional errors. Such an acknowledgment carries significant legal implications, emphasizing the importance of consulting with an experienced IRS tax attorney to navigate this complex requirement.
- Comprehensive Narrative Disclosure
Applicants must provide a detailed narrative outlining the specifics of their noncompliance, including the roles of all involved parties and any interactions with advisors. This comprehensive disclosure is essential for the IRS to fully understand the context and extent of the noncompliance. Crafting such a narrative requires meticulous attention to detail and a thorough understanding of tax law, areas where a seasoned tax attorney can provide invaluable assistance.
- Accelerated Documentation Deadlines
After the preclearance letter, the IRS requires Part II of Form 14457 within 45 days. This is not a blanket deadline after preliminary acceptance for every tax return and financial document; the assigned civil examiner requests documents separately. A one-time 45-day extension may be granted, but failure to comply within these timeframes can result in removal from the program. Given the tight deadlines, prompt action and thorough preparation are crucial, underscoring the need for professional guidance to ensure compliance.
- Requirement for Full Payment
Current IRS VDP guidance requires payment in full or a full-pay installment agreement for taxes, interest and applicable penalties. Do not equate preclearance or preliminary acceptance with an immediate-payment deadline for every assessed amount. This stringent requirement highlights the importance of financial readiness and may necessitate strategic financial planning, areas where a tax attorney’s expertise is beneficial.
Implications for Taxpayers
These changes reflect the IRS’s intensified focus on voluntary disclosures, aiming to enhance tax compliance and ensure that taxpayers fully address their tax liabilities. For individuals and businesses considering this program, it is imperative to consult with a qualified IRS tax attorney. Professional legal counsel can help navigate the increased requirements, assess associated risks, and develop a strategic approach to achieve the best possible outcome.
About Segal, Cohen & Landis, P.C. (SCL)
Review the relevant notices, filing history, records, and deadlines before choosing a response. Evaluate professional assistance according to the facts, applicable law, and agreed scope of representation.
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- Back Taxes: Assisting clients in resolving outstanding tax debts and negotiating favorable terms with the IRS.
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- Offer in Compromise: Negotiating settlements with the IRS to reduce the total tax liability owed.
- Unfiled Tax Returns: Assisting clients in preparing and filing overdue tax returns to achieve compliance and avoid penalties.
Why Choose Segal, Cohen & Landis, P.C.?
- Review the relevant notices, filing history, records, and deadlines before choosing a response. Evaluate professional assistance according to the facts, applicable law, and agreed scope of representation.
- Review the relevant notices, filing history, records, and deadlines before choosing a response. Evaluate professional assistance according to the facts, applicable law, and agreed scope of representation. Related resources: Expert Attorneys:.
- Personalized Service: Clients receive direct attention from senior attorneys, ensuring that each case is handled with the utmost care and expertise.
- Nationwide Availability: We serve clients in all 50 states, providing accessible and responsive legal services wherever you are located.
Contact Us
If you are facing tax issues or considering the IRS Voluntary Disclosure Practice, contact Segal, Cohen & Landis, P.C. for a free confidential consultation. Our experienced tax attorneys are available 24/7 to assist you in navigating the complexities of tax law and achieving a favorable resolution.
- Phone: (310) 285-3999
- Email: info@scltaxlaw.com
Facing tax challenges can be daunting, but with the right legal support, you can navigate the process confidently and effectively. Segal, Cohen & Landis, P.C. is dedicated to providing the expertise and personalized service you need to resolve your tax issues and secure your financial future.
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Segal, Cohen & Landis, P.C. — Beverly Hills. Serving clients nationwide.
Samuel Landis, Esq.
LL.M. (Tax) · Selected to Super Lawyers®
Sam Landis is a Beverly Hills IRS tax attorney specializing in IRS collection defense, audit representation, and international tax compliance for foreign nationals and US expats.