State Bar of California
Super Lawyers

What is the Difference Between a ''Noisy Voluntary Disclosure'' and a ''Soft or Quiet Voluntary Disclosure''?

There are two schools of thought regarding how to make a voluntary disclosure. The first is that it should be done quietly. Send in new or amended tax returns, with a check, and hope that it gets processed without ever hearing from the Criminal Investigation Division (“CI”). This is known as a “quite voluntary disclosure” or “soft voluntary disclosure”. The second approach is a “noisy voluntary disclosure” in which a meeting is arranged with CI to discuss whether or not the taxpayer’s facts and circumstances meet the terms of the IRS voluntary disclosure policy, and whether or not the IRS has already begun an investigation of the taxpayer of which the taxpayer is unaware.

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