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

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