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The IRS wants to encourage Voluntary Disclosure participation and reduce Taxpayer uncertainty, but its current Voluntary Disclosure Program is not set up for success according to the.
IRS announced revisions to Form 14457, 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.
IRS announced revisions to Form 14457, 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 apply for the VDP, a Taxpayer must first:
Fill out Part I of Form 14457, Voluntary Disclosure Practice Preclearance Request and Application PDF to request preclearance. Preclearance determines a Taxpayer’s eligibility for the program but does not guarantee preliminary acceptance into it. Part I can be faxed or emailed to IRS-CI. Part I is the Preclearance request and it is mandatory by IRS-CI.
Submit Part II of the Voluntary Disclosure Application within 45 days or make a written request for additional time once the Taxpayer has received preclearance confirmation. Extension requests are approved on a case-by-case basis. No more than one, 45-day, extension is permitted. Part II is the actual voluntary disclosure and must include a narrative statement of facts detailing the Taxpayer’s willful conduct.