IRS Criminal Investigation Chief Jarod Koopman said the agency is working to introduce the revised program before December, with a goal of resolving cases within 120 days after taxpayers complete the required submission. The overhaul will not create a separate disclosure process for digital assets; instead, cryptocurrencies will be handled through the same voluntary disclosure procedures used for other forms of tax noncompliance.
Koopman told attendees at the UCLA Extension Tax Controversy Conference that penalties under the revised program would be substantially lower than those currently imposed, though he did not provide specific figures. The agency is also considering allowing taxpayers to settle outstanding liabilities through installment plans or offers in compromise.
The proposed changes mark a shift from the existing process, which can take a year or longer to complete. The current voluntary disclosure program is intended for taxpayers whose willful failure to comply with tax laws could expose them to criminal prosecution, rather than those who made unintentional reporting errors.
Separately, lawmakers are considering a distinct voluntary disclosure program tailored to crypto taxpayers, including those who made unintentional reporting errors. Section 502 of the proposed Digital Asset Tax Certainty Act would establish a process for correcting past violations with defined penalties, differing from the IRS’s existing program, which primarily addresses willful tax noncompliance. The bill cleared the House Ways and Means Committee in September.
