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Negotiating State Tax Settlements: Voluntary Disclosure, Amnesty Agreements, and Audit Strategies

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Wednesday, September 23, 2020

Recorded event now available

or call 1-800-926-7926

This course will explain the methods available for resolving past multistate tax liability for businesses and advisers to taxpayers selling products or services in several states. Our panel of state and local tax veterans will cover voluntary disclosure programs, amnesty arrangements, and negotiating settlements for taxpayers struggling to reconcile past debts.


Thirty-six states participate in the Multistate Voluntary Disclosure Program (MVDP). The program allows taxpayers with liability in many states to negotiate a settlement under uniform procedures. The procedure requires filing past returns and payment of tax with the possibility of abatement of penalties for those periods. Of the member states, California and New York, for example, are noticeably missing.

Suffering from lack of revenue during the pandemic, some states are considering amnesty agreements as a revenue source. Ohio offers relief from penalties, interest, and prosecution for delinquent taxpayers who come forward during the three months between Jan. 1 to Mar. 31, 2021.

Taxpayers suffering from unreported state liability must decide whether to make a voluntary disclosure, wait for a potential state amnesty program, or a state audit. For those taxpayers who are audited by a state, handling the audit effectively can reduce penalties, interest, and the tax burden of noncompliance. Understanding how to negotiate a settlement properly, how to beneficially manage the statute of limitations, and when litigation may be the best option are all critical concerns.

Listen as our panel of SALT experts walks you through the available options for settling past state tax obligations.



  1. Targeted multistate taxpayers
  2. Potential liability
  3. Voluntary disclosure agreements
  4. Amnesty arrangements
  5. Negotiating settlements
  6. Litigation
  7. Best practices


The panel will discuss these and other critical issues:

  • Which taxpayers do states target for past unpaid liabilities?
  • Which taxpayers benefit the most from a voluntary disclosure agreement?
  • What are strategies to negotiate a better settlement?
  • What states currently offer VDAs and amnesty agreements?
  • Is it ever better to wait for the states to discover a taxpayer's past obligations?


Roberts, Stacey
Stacey L. Roberts, CPA

State and Local Tax Director

Ms. Roberts has been making SALT less taxing for thousands of businesses over the last 25 years. As a director of the...  |  Read More

Vorndran, Judith
Judith B. Vorndran, JD, CPA, MSBA


Ms. Vorndran helps clients and tax professionals navigate the morass of state and local tax issues with the goal of...  |  Read More

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