Carolyn Schenck Comments on Potential Changes to the IRS Voluntary Disclosure Program in Tax Notes

The IRS is planning to amend its voluntary disclosure practice in 2026 and will offer the tax community an opportunity for notice and comment, according to IRS Criminal Investigation division Chief Guy Ficco.

The comment period for the 2026 revisions to the voluntary disclosure program should be 90 days, Ficco said December 12 at an American Bar Association Section of Taxation conference in Las Vegas.

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Former IRS National Fraud Counsel [and Member] Carolyn Schenck said, “Taxpayers and attorneys should carefully evaluate potential defendants’ criminal tax exposure when considering whether it would be wise to wait for any potential changes.”

To read the article in full, please visit Tax Notes’ website.