Coming in from the Cold - Risks and Reward of the Revised IRS Voluntary Disclosure Practice

Level: Advanced
Runtime: 94 minutes
Recorded Date: November 18, 2020
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  • Who should use the voluntary disclosure practice?
  • What’s the process for entering the voluntary disclosure practice?
  • How are cases resolved by civil exam after preliminary acceptance?
  • Does the Service accept input from practitioners?
Runtime: 1 hour, 34 minutes
Recorded: November 18, 2020


In November 2018, the IRS revised its long-standing voluntary disclosure practice. In April 2020, the IRS released an updated Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, with detailed instructions, offering valuable insight into the internal processing of a voluntary disclosures, eligibility, and revocation of preliminary approvals. With this information in hand, practitioners are trying to determine whether a voluntary disclosure is best for their clients, and the IRS is here to help!

Dan Price is a senior attorney with IRS Office of Chief Counsel and a member of the team that drafted the voluntary disclosure guidance. Dan will discuss his history with voluntary disclosures, what led to the new penalty framework, eligibility and compliance under the revised practice, and some of the issues the IRS is considering for future guidance.

This program was recorded on November 18th, 2020.

Provided By

American Bar Association


Daniel N. Price

Attorney, Office of Chief Counsel
U.S. Dept. of Treasury

Daniel N. Price is an attorney with the Office of Chief Counsel of the Internal Revenue Service (SB/SE Division) in Austin, Texas. Dan advises the IRS on national issues relating to Offshore Voluntary Disclosure Programs and the Streamlined Filing Compliance Procedures. His role in these special compliance initiatives includes planning, developing, and writing FAQs for public guidance, developing new forms, speaking at practitioner events, training and advising IRS personnel, developing job aids and templates, and much more.

Dan has a tax litigation background and also handles complex cases involving tax fraud and willful FBAR violations. Dan received an undergraduate degree in accounting, summa cum laude, from the University of Texas at San Antonio, and a master’s degree in accounting from Trinity University.

Dan received his J.D., with honors, from the University of Texas School of Law. During the first year of law school, Dan passed the Uniform CPA exam (not licensed as a CPA).

Caroline D. Ciraolo

Kostelanetz & Fink LLP

During her tenure with the Justice Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal and appellate sections. Under her leadership, the Division reached agreements with 80 Swiss financial institutions that admitted to facilitating tax evasion and the avoidance of reporting requirements by U.S. account holders, and imposed and collected more than $1.36 billion in penalties, increased civil and criminal enforcement with respect to offshore tax evasion, employment tax violations, and traditional tax offenses, assisted the IRS through summons enforcement proceedings, and engaged in affirmative and defensive litigation involving abusive tax shelters and schemes, refund claims, and challenges to statutes and regulations.

Prior to joining the Department, Caroline was Chair of the Tax Controversy and Litigation practice group of a regional firm in Baltimore, Maryland, where she represented individuals and businesses in all phases of state and federal civil tax controversies and criminal tax investigations and prosecutions. She has appeared before the IRS, the Comptroller of Maryland and the D.C. Office of Tax and Revenue, the Maryland Tax Court, the U.S. Tax Court, U.S. District Courts, the Maryland circuit and appellate courts and the U.S. Court of Appeals for the Fourth and Federal Circuits.

Caroline is a Fellow and Officer of the American College of Tax Counsel and Chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association’s Section of Taxation. Caroline has also served as an instructor with the IRS Military Volunteer Income Tax Assistance program at Ft. George G. Meade in Maryland.

She has been recognized by Chambers (Tax Fraud (Nationwide), Tax (DC)), Benchmark, Best Lawyers in America (Litigation and Controversy – Tax, Tax Law), Super Lawyers (Top 10 Attorneys in Maryland, Maryland cover story in 2013, DC), Euromoney Legal Media Group’s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014), and The Daily Record’s Top 100 Women Circle of Excellence. Caroline is a recipient of the ABA Section of Taxation’s Janet Spragens Pro Bono Award, and in January 2017, she was recognized by IRS Chief Counsel William Wilkins with the Chief Counsel Award, the highest honor that can be conferred by that office.

Caroline is an Adjunct Professor at the Georgetown University Law Center (International Tax Controversies, Criminal Tax Law and Procedure) and University of Baltimore School of Law Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes).

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