Description
IRS modified its VDP in June 2024. The revisions appear to be minimal; however, the significance of these changes cannot be understated.
Before the latest revisions, taxpayers attached a narrative explaining their noncompliance, often avoiding a direct confession of willful noncompliance. The updated Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, contains two new boxes. One asks the taxpayer to check a box affirming their misrepresentations were willful. The other new box requires that applicants "have prepared and will hold all required documents to provide to the examiner upon initial contact, including, ... amended returns, bank statements, and financial statements." Tax advisers and their clients who may have underreported income must understand the new program requirements so that these taxpayers can potentially avoid criminal prosecution.
Listen as our panel of respected litigation experts reviews the updated application process of the IRS' VDP.
Presented By
Mr. Roberts is a firm Partner practicing in the areas of Tax Controversy, Estate and Gift Tax Litigation, White Collar and Government Regulatory Litigation, Income Tax and Business Planning, and Cryptocurrency and Digital Assets. He is Board Certified in Tax Law by the Texas Board of Legal Specialization. Mr. Roberts is a tax litigator and trusted advisor with extensive experience assisting both U.S. and international clients in successfully resolving various federal tax controversies, including civil and criminal liability cases. His expertise covers a broad spectrum of issues, such as tax audits, investigations, litigation, appeals, and collection matters.
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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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Date + Time
- event
Wednesday, December 18, 2024
- schedule
1:00 p.m. ET./10:00 a.m. PT
- 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
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
Learning Objectives
After completing this course, you will be able to:
- Identify taxpayers who should consider voluntary disclosure
- Determine common reasons applications for voluntary disclosure are denied by the IRS
- Ascertain how Form 14457, VDP Preclearance Request and Application, changes could impact applicants
- Decide what type of activities are eligible for voluntary disclosure
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of individual income taxation, including itemized deductions, individual income tax credits, net operating loss limitations including carrybacks and carryforwards.
BARBRI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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