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2022 Update to the Form 14457, Voluntary Disclosure Practice Preclearance Request

On February 15, 2022, the IRS announced an update to the Form 14457, 'Voluntary Disclosure Practice Preclearance Request'.

Noncompliance with foreign reporting obligations such as the FBAR and the Form 8938 ‘Statement of Foreign Financial Assets’ can result in fines, penalties, or even criminal prosecution. Understanding that noncompliance occurs with a wide variety of taxpayers for various reasons, the IRS has several options to correct noncompliance:

1. The Streamlined Filing Compliance Procedures

2. Delinquent International Information Return Submission Procedures

3. Delinquent FBAR Submission Procedures

4. IRS Criminal Investigation Voluntary Disclosure Practice (Form 14457)

5. Relief Procedures for Certain Former Citizens

The Form 14457 permits taxpayers who may face criminal prosecution for willful violation of tax law to voluntarily disclose information to the IRS that they failed to previously disclose.

Updates and additions to the form include:

  • IRS Criminal Investigation now accepts photocopies, facsimiles and scans of taxpayer signatures instead of mailing the documents

  • An expanded section for reporting virtual currency

  • A penalty structure for employment tax and estate and gift issues

  • A check-box for inability to pay in full


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