IRS Seeks to Revive its Voluntary Disclosure Practice
January 20, 2026 | New York Law Journal
On December 12, 2025, Guy Ficco, the IRS’s Chief of Criminal Investigation, announced that the IRS would review and revise its Voluntary Disclosure Practice (VDP), which allows taxpayers with criminal exposure to come into compliance and reduce the risk of prosecution. In his latest New York Law Journal article, Morvillo Abramowitz Grand Iason & Anello partner Jeremy Temkin outlines the background of the VDP, describes some of the current challenges faced by taxpayers and practitioners, and discusses the value of a reinvigorated VDP as a viable option for bringing taxpayers into compliance. Temkin concludes that without a robust civil and criminal enforcement regime, the IRS will need to make the application process less onerous and provide clear and consistent guidance, efficient processing, and genuine economic incentives to convince taxpayers and practitioners that VDP is the best way to address past noncompliance.
