Posts tagged new guidance on voluntary tax disclosures.

A bedrock of IRS administrative practice has been the voluntary disclosure.   Where an individual or business has not filed tax returns or believes they may have criminal tax exposure for prior actions, IRS procedures have long-sanctioned a form of  “criminal tax amnesty” if the taxpayer voluntarily comes forward before being contacted by the IRS, discloses his tax misdeeds, fully cooperates to correct the back tax issues, and then becomes compliant going forward.  In exchange for this “voluntary disclosure”, while criminal tax prosecution may not be recommended, the ...

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