On November 18, 2020, Caroline D. Ciraolo moderates a discussion with Daniel N. Price, IRS Office of Chief Counsel, entitled “Coming in from the Cold – Risks and Rewards of the Revised IRS Voluntary Disclosure Practice” at ABA Tax Section Civil & Criminal Tax Penalties Committee.

Description: In November 2018, the IRS revised its long-standing voluntary disclosure practice. In April 2020, the IRS released an updated Form 14457,Voluntary Disclosure Practice Preclearance Request and Application, with detailed instructions, offering valuable insight into the internal processing of a voluntary disclosures, eligibility, and revocation of preliminary approvals. With this information in hand, practitioners are trying to determine whether a voluntary disclosure is best for their clients, and the IRS is here to help! Dan Price is a senior attorney with IRS Office of Chief Counsel and a member of the team that drafted the voluntary disclosure guidance. Dan discusses his history with voluntary disclosures, what led to the new penalty framework, eligibility and compliance under the revised practice, and some of the issues the IRS is considering for future guidance. Following the discussion, Dan takes questions from the audience.

Speakers:
Caroline D. Ciraolo, Kostelanetz & Fink, LLP (Moderator)
Daniel N. Price, IRS Office of Chief Counsel

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