IRS Clarifies Voluntary Disclosure Practice
Tax problems almost always lead to stress and sleepless nights. But now, thanks to clarity from the IRS, certain tax problems can be put to bed with complete certainty.
December 19, 2018 at 09:14 AM
5 minute read
Tax problems almost always lead to stress and sleepless nights. But now, thanks to clarity from the IRS, certain tax problems can be put to bed with complete certainty.
The IRS recognizes that it cannot prosecute and audit every fraudulently filed tax return. Therefore, for decades, the IRS has encouraged taxpayers and small businesses with tax problems to voluntarily come forward and clean up their tax issues prior to ever being contacted by the IRS. This process is called voluntary disclosure and it has existed in various forms for decades. On Nov. 29, the IRS provided new guidance to American taxpayers about how to cure past tax problems in a way that will certainly avoid criminal prosecution.
For nearly the past decade, the IRS had a special form of voluntary disclosure available to American taxpayers with undeclared foreign assets, including bank accounts, corporations, some real estate and trusts. More than 56,000 American taxpayers took advantage of various iterations of the IRS's Offshore Voluntary Disclosure Program, generating more than $11.1 billion in back-taxes and penalties. The Offshore Voluntary Disclosure Program offered a fixed, reduced penalty—and a get-out-of-jail-free card, in exchange for voluntarily coming forward. To the surprise of many, the IRS announced the closure of the Offshore Voluntary Disclosure Program in September 2018.
However, new guidance announced last week reopens the door to voluntary disclosures by Americans with undeclared foreign assets. But unlike before, the IRS is no longer offering a fixed-amount reduced penalty for voluntarily coming into compliance. Under the new guidance, each case will be examined on a case-by-case basis. And the burden will rest on the taxpayer to present convincing evidence to justify why potentially steep penalties should not be imposed. Taxpayers will still be given assurance that their matter will remain civil, so long as they cooperate with the audit.
While there are many taxpayers still with undeclared assets offshore, the new guidance more explicitly and favorably reaches out to those with domestic tax issues. Now, small businesses and individual taxpayers can clean up their domestic tax problems with a civil fraud penalty that is applied to just one tax year. Ordinarily, the IRS may seek penalties each year for conduct that spanned multiple years. Under the new guidance, the IRS reserves the right to seek additional penalties if the facts so dictate, but for most the newly announced framework is an invitation to get right without the fear of prosecution and with a significant reduction in exposure to civil penalties.
It is important to remember that the reduced penalties announced in the new guidance only apply to American taxpayers who are not already under audit or criminal investigation. The IRS now has created a process for taxpayers to see if they are eligible to participate in the voluntary disclosure program. This process is called pre-clearance and it requires the submission of certain biographical information to the IRS.
If a taxpayer is cleared to participate, they must then certify that any disclosed income was from a legal source. This means that the unreported income cannot be derived from what is otherwise an illegal activity, like drug dealing or money laundering. Assuming the money is from a legal source, the taxpayer or small business must then provide a statement to the IRS that details the facts and circumstances, assets, related parties and any professional advisers who were involved in the noncompliance. The IRS will review this information and then will provide the taxpayer with written confirmation that so long as they cooperate with a civil exam, their matter will never be pursued criminally by the IRS. This is a huge relief for many taxpayers who have had lingering tax problems that have been ongoing for many years.
Taxpayers are then required to file amended tax returns for six years. These tax returns will then be reviewed by a civil examiner at the IRS. Should the civil examiner agree with the amended tax returns filed by the taxpayer, the matter will be closed. If there are any disagreements, the taxpayer now has the right to take the matter to appeals within the IRS for review.
Many businesses, big or small, have something on the books that needs to be corrected. Now, you can clean up the mess without the fear of going to jail. The penalty framework is also inviting. For those with a domestic issue, the reduced penalties are very appealing. And for those with foreign issues, you can now present your case on an individual basis in order to avoid steep penalties.
For the American taxpayer who has had sleepless nights as a result of a lingering tax problem, now is the time to get right with Uncle Sam.
Jeffrey A. Neiman is an attorney with Marcus Neiman & Rashbaum, where he focuses his practice on criminal and civil tax controversy matter. Previously, Neiman was a federal prosecutor in Washington, D.C. and in Miami, Florida.
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