IRS Voluntary Disclosure Practice (VDP)
Offshore Voluntary Disclosure Attorney & CPA
Los Angeles • Orange County • Nationwide Representation
If you have unreported foreign income, undisclosed offshore accounts, incomplete international information returns, or prior tax filing errors, you may still have options — but timing and legal strategy are critical.
As a dual-licensed Tax Attorney and CPA, I integrate legal analysis with technical tax compliance to help clients:
- Correct past reporting failures
- Reduce civil penalty exposure
- Minimize criminal risk where applicable
- Navigate complex international regulatory frameworks
Understanding Your Compliance Path
Not all disclosure cases are the same. The IRS distinguishes primarily between willful and non-willful violations. The correct classification significantly affects your exposure.
- Willful Violations
(Potential Criminal Exposure — Voluntary Disclosure Required)
When a taxpayer knowingly failed to report income, foreign accounts, or information returns, the matter may fall under the IRS Voluntary Disclosure Practice (VDP).
IRS Voluntary Disclosure Practice (VDP)
The IRS Voluntary Disclosure Practice allows taxpayers to voluntarily correct past tax violations before the IRS initiates an audit or enforcement action.
Although taxes, interest, and penalties must still be paid, properly executed disclosures typically:
- Substantially reduce criminal prosecution risk
- Provide a structured resolution process
- Reduce uncertainty compared to waiting for enforcement
The former Offshore Voluntary Disclosure Program (OVDP) ended in 2018. The current disclosure process is administered through the IRS Criminal Investigation (CI) division and applies to both domestic and offshore matters.
The process generally includes:
- Preclearance request to IRS CI
- Formal voluntary disclosure submission
- Amended or delinquent returns
- Detailed narrative explanation
- Civil resolution phase
For official IRS guidance, visit:
IRS Voluntary Disclosure Program
Important: VDP does not grant automatic immunity. Proper legal analysis is essential before submission.
- Non-Willful Violations
(Civil Compliance Programs Available)
If the failure to report was due to negligence, misunderstanding, or lack of knowledge — and not intentional concealment — different programs may apply.
Streamlined Filing Compliance Procedures
Designed for taxpayers who failed to report foreign financial assets and income, but whose conduct was non-willful.
- Streamlined Foreign Offshore Procedures – For U.S. taxpayers residing abroad
- Streamlined Domestic Offshore Procedures – For U.S. taxpayers residing in the United States
These programs can significantly reduce penalties when eligibility requirements are met.
Additional Compliance Options
Depending on your facts, the following may apply:
- Delinquent FBAR Submission Procedures – For unfiled FinCEN Form 114
- Delinquent International Information Returns Submission Procedures – For missed Forms 5471, 3520, 8865, 8621, etc.
Each option has strict eligibility standards. An incorrect submission can trigger examination or criminal referral.
Scope of Representation
We assist individuals, closely held businesses, and international families with:
- IRS Voluntary Disclosure Practice (VDP)
- Streamlined Domestic & Foreign Offshore Procedures
- FBAR (FinCEN Form 114) & FATCA (Form 8938) compliance
- Foreign asset reporting (Forms 5471, 8865, 8621, 3520)
- Unfiled foreign income & amended returns
- Civil penalty mitigation & IRS examination defense
- International tax resolution & Offer-in-Compromise
- OFAC compliance risk assessment
- Anti-Money Laundering (AML) exposure review
- Cross-border wealth transfer & foreign gift reporting
Why Dual Legal & CPA Representation Matters
Offshore disclosures sit at the intersection of:
- Tax law
- Criminal exposure analysis
- Civil penalty structure
- Financial reporting
- International regulatory compliance
As both Attorney and CPA, I evaluate legal risk and financial exposure together — not in isolation.
Disclaimer: The above information is provided for general informational purposes only and does not constitute legal or tax advice. Each case is fact-specific and requires individualized analysis.
Confidential Consultation
📞 Toll-Free: 1-877-687-7558
📞 Los Angeles: (310) 719-1040
📞 Orange County: (714) 546-4272
📧 taxattorney@zfcpa.com
Recognitions:
Rated 10 of 10 by Avvo
TOP Tax Attorney Ranked by Coast Magazine
Harvard Law School–Executive Programs in Negotiation & Leadership
Massachusetts Institute of Technology (MIT)–Executive Certificate in Blockchain Technologies: Basis of Cryptocurrency
