New IRS Voluntary Disclosure Program: Streamlining Acceptance, Avoiding Criminal Prosecution
Revisions to Form 14457, VDP Preclearance Request and Application
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will explain the Internal Revenue Service's new Voluntary Disclosure Program (VDP), subtly introduced by the IRS in June 2024. Our panel of seasoned tax controversy attorneys will discuss the current three-step process that includes preclearance, provide examples of applications, and point out the primary causes of rejections of these claims.
Outline
- Voluntary Disclosure Program: introduction
- Eligible taxpayers
- Steps
- Recent changes
- Form 14457, VDP Preclearance Request and Application – Part I
- Form 14457, VDP Preclearance Request and Application – Part II
- Amended returns, required payments, and documentation
- Rejections
Benefits
The panel will cover these and other critical issues:
- The IRS' new preclearance process for VDP applications
- The ramifications of checking the new willful conduct box
- Potential and frequent reasons VDP applications are rejected
- Taxpayers who are eligible for or should consider voluntary disclosure
Faculty
Matthew L. Roberts, J.D., LL.M.
Partner
Gray Reed
Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients... | Read More
Mr. Roberts is a tax litigator and trusted advisor with considerable experience helping U.S. and international clients successfully resolve all types of federal tax controversies involving civil or criminal liability, from tax audits and investigations to litigation, appeals and collection matters. Having served nearly three years as an attorney-advisor to the Chief Judge of the U.S. Tax Court in Washington, D.C., Mr. Roberts brings unique insight to navigating intricate government processes and developing innovative and cost-effective solutions to his clients’ tax problems. His client list spans many industries and ranges from individuals and entrepreneurs to non-profits, trusts and estates, partnerships and corporations.
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Joshua D. Smeltzer
Partner
Gray Reed
Mr. Smeltzer is Board Certified in Tax Law by the Texas Board of Legal Specialization. He focuses his... | Read More
Mr. Smeltzer is Board Certified in Tax Law by the Texas Board of Legal Specialization. He focuses his practice on defending taxpayers in all stages of civil and criminal tax proceedings, including sensitive audits and examinations. Mr. Smeltzer frequently represents corporations, complex partnerships, family offices, estates and trusts, and high-net worth individuals. His practice encompasses a variety of industries, with special expertise in real estate, energy, insurance, private equity, digital assets and blockchain technology. Mr. Smeltzer uses his background as a former U.S. Department of Justice lawyer to provide first-hand knowledge when the government is involved in litigation in designing an effective plan to litigate disputes, minimize risks and achieve as many client goals as possible. He has deep litigation and trial experience, both as a private and government lawyer, in controversies ranging from $500,000 to more than $1.5 billion.
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