IRS to Revise Criminal Voluntary Disclosure Program (1)

December 12, 2025, 7:23 PM UTCUpdated: December 12, 2025, 10:49 PM UTC

The IRS intends to revise a program that allows taxpayers to disclose possible tax fraud and reduce penalties.

The changes to the voluntary disclosure program aim to make the program more consistent and predictable for taxpayers, said IRS Criminal Investigation Chief Guy Ficco during a Friday panel at the American Bar Association’s 2025 Criminal Tax Fraud and Tax Controversy Conference in Las Vegas. The changes come as the IRS and its criminal division are grappling with a workforce reduction amid the Trump administration’s efforts to downsize the federal government.

The program revisions will be released publicly in early 2026 with ...

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