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Voluntary Disclosure

International Income and Asset Disclosures

McMahon & Tivnan regularly counsels clients through the IRS’s general Voluntary Disclosure Program to civilly resolve a large variety of tax non-compliance that could otherwise expose a client to both civil and criminal penalties. The IRS general Voluntary Disclosure Program is available to taxpayers with either domestic or international compliance errors of which the IRS is unaware.

Domestic Issue Disclosures

The IRS general Voluntary Disclosure Program has always been available to taxpayers who knowingly violated IRS filing and paying obligations, despite the IRS’s recent focus and use of a similar program for its international enforcement effort. For any situation in which a taxpayer may have knowingly violated his or her tax obligations that the IRS does not yet know about, the IRS Voluntary Disclosure programs promises that no referral will be made seeking criminal prosecution provided the taxpayer corrects and fully pays for the error. McMahon & Tivnan has guided many clients through this process achieving agreed resolutions with no criminal proceedings.


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