Segal, Cohen & Landis, P.C.
Come Forward Before the IRS Comes to You
IRS tax attorneys — Beverly Hills, CA. National representation.
The IRS Criminal Investigation Voluntary Disclosure Practice addresses willful tax noncompliance involving legal-source income. A truthful, complete and timely disclosure, cooperation and payment arrangements may reduce prosecution risk, but do not guarantee immunity. Timeliness can be lost before direct IRS contact: a civil examination, criminal investigation, relevant third-party information or information from a criminal enforcement action can disqualify a disclosure. Penalties depend on the applicable procedures and facts; proposed changes are not treated as effective rules.
How We Help
Our Approach to IRS Voluntary Disclosure Attorney
VDP vs. Streamlined Filing Analysis
Streamlined procedures are for eligible individual taxpayers, including estates of individuals, who certify that the relevant failures were non-willful. An IRS civil examination for any tax year, or an IRS criminal investigation, makes a taxpayer ineligible. The domestic track requires previously filed returns for the relevant three years and generally a 5% miscellaneous offshore penalty. Qualifying foreign-track submissions receive specified penalty relief. Tax and interest remain payable, and neither track guarantees immunity from audit or prosecution.
Offshore Voluntary Disclosure
Offshore cases typically involve unreported foreign bank accounts, FBAR violations, Form 8938 failures, foreign trust reporting, and foreign income. We quantify the full scope of noncompliance, assemble the required filings, calculate penalties, and submit a complete VDP or streamlined disclosure.
Domestic Voluntary Disclosure
Domestic VDP covers unreported income from U.S. sources — cash businesses, self-employment income, bartering income, or other situations where tax was not properly reported. We assess criminal risk, prepare amended returns, and navigate the disclosure process.
Cryptocurrency Voluntary Disclosure
Cryptocurrency tax compliance is increasingly scrutinized by the IRS. Unreported gains from Bitcoin, Ethereum, NFTs, and other digital assets can be significant. We reconstruct cryptocurrency transaction history and design disclosures that minimize penalties and exposure.
How It Works
The Resolution Process
Risk Assessment
We analyze the facts — scope of noncompliance, years involved, amounts, asset locations — to assess criminal and civil risk and identify the right disclosure vehicle.
Program Selection
We advise on VDP, streamlined domestic, streamlined foreign, or amended return filing — based on willfulness, geography, and risk profile.
Return Preparation
We prepare all required amended returns, FBARs, Forms 8938, and other required filings for all applicable years.
Submission and Negotiation
We submit the disclosure, respond to IRS follow-up, and negotiate penalties where possible.
Ready to Resolve Your Tax Problem?
Our attorneys have helped thousands of clients resolve IRS matters. Your consultation is free and confidential.
Common Questions
Frequently Asked Questions
What is the difference between Voluntary Disclosure and Streamlined Filing?+
Streamlined procedures are for eligible individual taxpayers, including estates of individuals, who certify that the relevant failures were non-willful. An IRS civil examination for any tax year, or an IRS criminal investigation, makes a taxpayer ineligible. The domestic track requires previously filed returns for the relevant three years and generally a 5% miscellaneous offshore penalty. Qualifying foreign-track submissions receive specified penalty relief. Tax and interest remain payable, and neither track guarantees immunity from audit or prosecution.
Does voluntary disclosure prevent criminal prosecution?+
The IRS Criminal Investigation Voluntary Disclosure Practice addresses willful tax noncompliance involving legal-source income. A truthful, complete and timely disclosure, cooperation and payment arrangements may reduce prosecution risk, but do not guarantee immunity. Timeliness can be lost before direct IRS contact: a civil examination, criminal investigation, relevant third-party information or information from a criminal enforcement action can disqualify a disclosure. Penalties depend on the applicable procedures and facts; proposed changes are not treated as effective rules.
Beverly Hills · Los Angeles · National
Segal, Cohen & Landis, P.C.
9100 Wilshire Boulevard, 601 East Tower, Beverly Hills, CA 90212
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