New facsimile filing procedure for Form 14457
Expanded disclosure for cryptocurrency
New penalty structure for cases involving employment, estate, and gift tax
New procedure for disclosing inability to pay tax liability, penalties, and interest in a voluntary disclosure
On Feb. 15, 2022, the IRS announced revisions to Form 14457, the Voluntary Disclosure Practice Preclearance Request and Application. The longstanding Voluntary Disclosure Practice is a way for taxpayers who have criminal exposure for willfully failing to comply with their U.S. reporting requirements to resolve the issue with the IRS. Although a voluntary disclosure does not guarantee immunity from prosecution, the government will consider the taxpayer’s effort to come into compliance when making a charging decision. The IRS reiterates that the Voluntary Disclosure Practice does not apply to taxpayers without criminal tax exposure. Whether or not a taxpayer behaved willfully requires a detailed analysis of the facts.
To initiate a voluntary disclosure, a taxpayer must file Form 14457 with IRS Criminal Investigation (IRS-CI) in two parts: (i) the taxpayer first files the Preclearance Request at Part I to determine whether he or she is eligible to make a voluntary disclosure; and (ii) if the taxpayer receives preclearance, they must file the Voluntary Disclosure at Part II within 45 days of the date of pre-clearance unless IRS-CI grants an extension. Taxpayers must...
The Presidency has dismissed Oyo State Governor Seyi Makinde’s claim that the Federal Government is withholding 250 billion in Nigeria LNG Limited (NLNG) dividends for each state, describing the a...