IRS has recently implemented significant changes to its Voluntary Disclosure Practice

The Internal Revenue Service (IRS) has recently implemented significant changes to its Voluntary Disclosure Practice, as detailed in the updated Form 14457, “Voluntary Disclosure Practice Preclearance and Application.” These revisions underscore the IRS’s commitment to enforcing tax compliance and present new challenges for taxpayers seeking to rectify past tax issues.

Key Updates to the Voluntary Disclosure Practice

1. 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.

1. 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.

1. Accelerated Documentation Deadlines

Upon preliminary acceptance into the program, taxpayers have a strict 45-day window to submit all pertinent tax returns and financial documents. 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.

1. Requirement for Full Payment

The revised practice mandates full payment of all taxes, interest, and penalties upon acceptance into the program. While alternative payment arrangements can be requested, the IRS requires clear evidence of the taxpayer’s ability to pay the total amount owed. 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.

Segal, Cohen & Landis, P.C. is a nationally acclaimed tax law firm with over 33 years of experience in resolving complex federal and state tax issues, including back taxes, audits, wage garnishments, and levies. Our team of expert tax attorneys specializes in IRS dispute and controversy resolution, offering personalized and accessible service to clients across all 50 states. We are committed to achieving the best possible outcomes for our clients, providing full-service representation and the protection of attorney-client privilege.

Services Offered

• Back Taxes: Assisting clients in resolving outstanding tax debts and negotiating favorable terms with the IRS.
• IRS Audit Representation: Providing expert guidance and representation during IRS audits to protect clients’ rights and interests.
• Wage Garnishment and Levy Relief: Implementing strategies to release wage garnishments and levies, ensuring financial stability for our clients.
• 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.?

• Extensive Experience: With over 33+ years in practice and more than 15,000 satisfied clients, our firm has a proven track record of success.
• Expert Attorneys: Our attorneys hold advanced degrees in tax law and specialize in IRS dispute resolution, ensuring knowledgeable and effective representation.
• 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: 866-899-2479
• 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.