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New IRS Voluntary Disclosure Program: Streamlining Acceptance, Avoiding Criminal Prosecution

Revisions to Form 14457, VDP Preclearance Request and Application

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
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Wednesday, December 18, 2024 (in 11 days)

1:00pm-2:50pm EST, 10:00am-11:50am PST

or call 1-800-926-7926

This webinar will explain the Internal Revenue Service's new Voluntary Disclosure Program (VDP), subtly introduced by the IRS in June 2024. Our panel of seasoned tax controversy attorneys will discuss the current three-step process that includes preclearance, provide examples of applications, and point out the primary causes of rejections of these claims.

Description

IRS modified its VDP in June 2024. The revisions appear to be minimal; however, the significance of these changes cannot be understated.

Before the latest revisions, taxpayers attached a narrative explaining their noncompliance, often avoiding a direct confession of willful noncompliance. The updated Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, contains two new boxes. One asks the taxpayer to check a box affirming their misrepresentations were willful. The other new box requires that applicants "have prepared and will hold all required documents to provide to the examiner upon initial contact, including, ... amended returns, bank statements, and financial statements." Tax advisers and their clients who may have underreported income must understand the new program requirements so that these taxpayers can potentially avoid criminal prosecution.

Listen as our panel of respected litigation experts reviews the updated application process of the IRS' VDP.

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Outline

  1. Voluntary Disclosure Program: introduction
  2. Eligible taxpayers
  3. Steps
    1. Recent changes
    2. Form 14457, VDP Preclearance Request and Application – Part I
    3. Form 14457, VDP Preclearance Request and Application – Part II
    4. Amended returns, required payments, and documentation
  4. Rejections

Benefits

The panel will cover these and other critical issues:

  • The IRS' new preclearance process for VDP applications
  • The ramifications of checking the new willful conduct box
  • Potential and frequent reasons VDP applications are rejected
  • Taxpayers who are eligible for or should consider voluntary disclosure

Faculty

Roberts, Matthew
Matthew L. Roberts, J.D., LL.M.

Partner
Gray Reed

Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients...  |  Read More

Smeltzer, Joshua
Joshua D. Smeltzer

Partner
Gray Reed

Mr. Smeltzer is Board Certified in Tax Law by the Texas Board of Legal Specialization. He focuses his...  |  Read More

Attend on December 18

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CPE On-Demand

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