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IRS Voluntary Disclosure Practice: The Last Off-Ramp Before Criminal Exposure

Wednesday, September 2, 2026 · 1:00 p.m.  |  Eastern Time (US & Canada) (GMT -4:00)

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WEBINAR ENDED
Presenter
1780501925-a78be6ea6bfac47c
Matt Eddleman
EA
Matt Eddleman brings more than two decades of professional experience in tax controversy, accounting, financial planning, and small business management to Frost Law's Tax Compliance team.
About
Program Field of Study: Taxes, Federal Tax Related Matters
Program Level: Basic
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: JWRXB-T-00027-26-O

When noncompliance is willful, streamlined filing isn't just unavailable: using it is a fraudulent certification that makes things worse. Learn how to trade prosecution risk for a negotiated civil resolution by attending this presentation that covers Voluntary Disclosure Practice (VPD) (IRM 9.5.11.9), the two-part Form 14457 process, the six-year lookback, the 75% civil fraud penalty on the single highest-liability year, how FBAR willfulness penalties stack on top, and the timeliness trap that kills a disclosure.
Agenda
  • Distinguish willful from non-willful conduct and correctly triage a client into SFCP vs. VDP.
  • Identify what IRS "awareness" events (exam, summons, whistleblower referral, etc.) foreclose VDP eligibility.
  • Understand Form 14457 Parts I and II, including what the Part II narrative must contain to avoid rejection.
  • Calculate the VDP civil resolution: the 75% fraud penalty on the highest-liability year plus layered FBAR penalties.
  • Explain the exposure created by a false non-willfulness certification under SFCP.
  • Advise clients on VDP's limits
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