Avoiding the Worst-Case Scenario: The IRS's Domestic Voluntary Disclosure Practice

By: Brian Ketcham

Most CPAs are now familiar with the IRS's heavily publicized Offshore Voluntary Disclosure Program (OVDP), which allows taxpayers with previously undeclared foreign assets to file amended tax returns and delinquent information returns in exchange for immunity from criminal prosecution and reduced civil penalties. Many, however, are unaware that the IRS has a long-standing policy permitting general voluntary disclosures involving domestic tax issues. 

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