News & Events

While taxpayers can use voluntary disclosures to resolve qualifying federal tax law violations, they can only do so if they make their disclosures in a “timely” manner. Among other things, this means that taxpayers must make their disclosures before the IRS opens an audit or investigation. If you are considering a voluntary disclosure, you should consult with an experienced Washington, D.C., international tax attorney before moving forward.

While submitting a voluntary disclosure can mitigate the consequences of failing to report foreign bank accounts to the federal government, strict eligibility criteria (including filing deadlines) apply. If a taxpayer who is not eligible attempts to submit a voluntary disclosure, this could lead to consequences that could—and should—have been avoided.

The IRS recently transitioned to a new penalty relief system for U.S. taxpayers. As of Summer 2026, taxpayers who have timely met their obligations for the past three years are eligible for the IRS’s Automatic Exemption from Penalty (AEP) for delinquent filings and payments. However, other enforcement risks remain, and delinquent taxpayers must make informed decisions about how best to deal with the IRS.

IRS Criminal Investigation (IRS CI) targets individual and corporate taxpayers suspected of a wide range of federal offenses—both tax-related and non-tax-related. When IRS CI investigations lead to federal indictments, targeted individuals and entities can face substantial penalties. The Washington, D.C. criminal tax lawyers at Thorn Law Group rely on extensive experience to provide strategic defense representation in these cases.

In July 2026, the Internal Revenue Service (IRS) published new regulations that identify Charitable Remainder Annuity Trusts (CRATs) as “listed transactions.” For U.S. taxpayers who use CRATs for tax mitigation purposes, managing compliance with the IRS’s listed transaction rules will be critical moving forward.