Article on The Future of Voluntary Disclosure

Noam Noked recently published an Article entitled, The Future of Voluntary Disclosure, Tax Law: Tax Law & Policy eJournal (2018). Provided below is an abstract of the Article:

This article calls for the IRS to adopt permanent voluntary disclosure procedures that incorporate specific features of the latest offshore voluntary disclosure program and correct some of its flaws. If the IRS does not provide new voluntary disclosure procedures for willful noncompliance, taxpayers will face uncertain penalties under the so-called quiet disclosures and the traditional voluntary disclosure practice outlined in the Internal Revenue Manual. That uncertainty – and the potential for inconsistent treatment of similarly situated taxpayers – would increase the costs of becoming compliant and ultimately discourage taxpayers from making voluntary disclosures.