Changes to IRS Voluntary Disclosure Program are Coming

I just returned from the 2025 Criminal Tax Fraud and Tax Controversy Conference in Las Vegas. This is always a spectacular conference where cutting edge civil and criminal tax controversy developments are discussed among the industry’s leading practitioners. This year, IRS Criminal Investigation (CI) Chief Guy Ficco announced that the IRS will be making changes to its voluntary disclosure program in 2026.

As background, the IRS voluntary disclosure program is a way for taxpayers to mitigate their risk of criminal prosecution and civil penalties by voluntarily coming forward and correcting their underlying compliance issues. It is a multistep process that requires (1) getting the IRS to confirm that the taxpayer is eligible for the voluntary disclosure program; (2) the taxpayer providing detailed information about their noncompliance; (3) the taxpayer actually correcting the noncompliance; and (4) the IRS performing an audit of the taxpayer’s corrections.
The changes to the program are anticipated to streamline some of the process, which should be a welcome development to both taxpayers and the IRS. We will learn more when the Department of Treasury and the IRS release proposed rules regarding the program’s changes. There will also be a 90-day period to comment on the proposed changes. I anticipate many practitioners and other stakeholders will submit comments.

Ultimately, the voluntary disclosure program can be a wonderful tool for taxpayers to “get right” with the IRS. If the IRS streamlines this process and makes it easier for taxpayers to fix their noncompliance, the program will become even more desirable. I will be carefully following the developments in the months to come, and I expect the Meadows Collier blog will share those developments as they unfold.

If you have any questions about correcting tax compliance issues, or any other civil or criminal tax issue, you can reach me at 214-749-2417 or jglassman@meadowscollier.com.