The IRS Criminal Investigation division has long had a program where taxpayers can voluntarily come forward and disclose prior non-compliance in exchange for the IRS not recommending criminal prosecution. These traditional domestic voluntary disclosures include a failure to file returns, omission of income, or overstated deductions. Colvin + Hallett attorneys draw on their experience to advise clients about whether, when, and how to make a voluntary disclosure in both the domestic and international sphere.

In the international arena, Colvin + Hallett has advised and guided over a hundred clients in the IRS’s Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) and its streamlined program for taxpayers who did not report foreign bank accounts, trusts, assets, or income requiring disclosure. We have deep expertise in the international compliance arena, which involves a complex web of rules, regulations, treaty provisions, and obligations thereunder that often ensnare the most sophisticated and well-intentioned taxpayers.

Case Studies

Represented business owner who was keeping two separate sets of books in voluntary disclosure.

Represented lawyer who failed to file personal and corporate returns for the law firm involving $2 million in unreported income.

Represented elected official who had failed to file returns for multiple years.

Represented taxpayers whose prior representative had entered them in the OVDP and calculated penalties of over $100,000; successfully argued that client was nominee and had no beneficial interest in the accounts, so no penalties were imposed.

Represented taxpayer who was not permitted to participate in OVDP because UBS had already turned over taxpayer’s name; ultimately obtained result for taxpayer more favorable than she would have otherwise received in the OVDP.

Assisted numerous clients who successfully transitioned into the streamlined program from the OVDP, receiving significant reduction in penalties.

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