Form 14457 (2019) – Updated Voluntary Disclosure Preclearance Letter

Form 14457 (2019) - Updated Voluntary Disclosure Preclearance Letter (Golding & Golding)

Form 14457 (2019) – Updated Voluntary Disclosure Preclearance Letter (Golding & Golding)

Form 14457: IRS Voluntary Disclosure Practice submissions are now made on the Updated Form 14457 (Voluntary Disclosure Preclearance Letter to the IRS).

Form 14457

The IRS recently made good on its promise from back in November 2018 (IRS Voluntary Disclosure updated Memo) to provide an updated voluntary disclosure practice preclearance request and application form.

IRS Voluntary Disclosure Preclearance requests will now be made on form 14457.

What is a Form 14457 Preclearance Request?

If you are going to make a voluntary disclosure to the IRS to report undisclosed income, assets, accounts, or investments – the IRS now requires that you use the updated form 14457 to make the request.

Let’s go through the form 14457 together:

Part I – General Instructions


Note: Use Part I of this form to make a preclearance request to determine whether you are eligible to use the voluntary disclosure practice.


Only submit Part 1 of this form for preclearance.


If you receive preclearance, proceed with submitting Part II to request preliminary acceptance. Submitting the information requested in Part I of this form does not guarantee acceptance. All answers and attachments must be in English.

Mailing Address: Internal Revenue Service

Attn.: Voluntary Disclosure Coordinator
2970 Market Street
1-D04-100
Philadelphia, PA 19104

Who is Making the IRS Voluntary Disclosure Application?

First, the IRS want to know what kind of person is making the application:

  • Individual
  • Partnership
  • Corporation
  • Trust
  • Executor

What Type of Voluntary Disclosure Application to the IRS is being Made?

Next, the IRS wants to know what type of disclosures are being made

  • Domestic issues
  • Offshore issues
  • Estate and gift issues
  • Employment tax issues
  • Virtual currency issues
  • Other issues

Biographical Information About the Applicant

The IRS also wants to know information about your background, including:

  • Your name
  • Social security or other identifying number
  • Date of birth
  • Telephone number
  • Street address
  • City
  • State
  • ZIP Code
  • Country
  • Occupation
  • Passport information

Tax Representative Information

The IRS wants information regarding your representative. This Information includes:

  • Name
  • Copier form 2848 (Power of attorney)
  • Telephone number
  • Fax Number
  • Street address
  • City
  • State
  • ZIP Code
  • Country

Additional General Background Questions


List any entities (corporations, partnerships, etc.) for which you are making a disclosure, include EIN if applicable. Further identification information for these entities will be required in Part II of this application


Do you believe that the IRS has obtained information concerning your tax liability


Disclose if you, your spouse or any related entities are currently under audit or criminal investigation by the Internal Revenue Service or any other law enforcement authority and if any income is sourced from an illegal activity


More Specific Questions


Has the IRS notified you, your spouse or any related entities that it intends to commence an examination or criminal investigation


Are you, your spouse or any related entities under criminal investigation by the Internal Revenue Service


Are you, your spouse or any related entities under criminal investigation by any law enforcement authority


Do you, your spouse or any related entities have income sourced from an illegal Activity


Schedule of Financial Accounts


List ALL noncompliant financial accounts you owned or controlled or were the beneficial owner of, either directly or indirectly.


The listings must cover the entire disclosure period as outlined in the Updated Voluntary Disclosure Practice Memorandum dated November 20, 2018.


This includes opened and closed accounts which held unreported funds during the disclosure period.


This includes accounts held through entities you owned or controlled or were the beneficial owner of, either directly or indirectly. Note: The entities will be further identified in Part II of this application.


Disclose all account numbers held at each financial institution.


Organize the account numbers in order of who held the account. Jointly held accounts should be identified as such and only listed once.


Account holders must match the disclosing taxpayer(s) from Lines 4 and 5, or an entity on Line 7 that will be subsequently disclosed in more detail in Part II after pre-clearance is received


If an account is closed, mark it with a “(CL)” after the account number.


You Need an Attorney and Law Firm that is Highly-Experienced

Our team has made more than 1000 offshore Disclosures (OVDP, Traditional Voluntary Disclosure, Streamlined, and Reasonable Cause/Delinquency) — including complex issues involving FATCA, PFIC, CFC, Foreign Mutual Funds, and more.

The area of law is always changing, and due to recent updates in the law, including changes to various international tax agreements, regulations, statutes, and enforcement procedures — oftentimes even a “simpler” FBAR disclosure becomes an incredibly complicated process. 

Golding & Golding is a full-service International Offshore Disclosure Law Firm and Tax Firm specializing exclusively in Offshore Disclosure matters, worldwide in 70-different countries.

We routinely represent clients in:

  • FATCA
  • FBAR
  • PFIC
  • Offshore Assets
  • Offshore Investments
  • Offshore Income
  • Offshore Accounts
  • Foreign Businesses
  • Foreign Life Insurance
  • Foreign Cryptocurrency
  • Foreign Real Estate
  • Foreign Gifts
  • Foreign Inheritance
  • International Tax Investigations
  • Tax Treaty Analysis
  • “Cross-Border” issues

5 Easy Ways to Vet Out IRS Offshore Disclosure Attorneys

Offshore disclosure is like a puzzle. And, you need all the pieces of the puzzle to complete the task at hand. 

There is a reason why the top tax attorneys nationwide in IRS Offshore Disclosure generally will have five (5) main qualifications:

  • Board Certified Tax Law Specialist (less than 1% of attorneys nationwide)
  • Enrolled Agent or CPA status
  • LL.M. (Masters in Tax)
  • Litigation & Trial Experience
  • A Firm that Specializes exclusively in IRS Offshore Disclosure

Hiring an Offshore Disclosure Lawyer – 5 Types of Lawyers to Avoid

4 Types of IRS Voluntary Disclosure Programs

There are typically four types of IRS Voluntary Disclosure programs, and they include:

Contact Us Today; Let us Help You.

International Tax Lawyers - Golding & Golding, A PLC

International Tax Lawyers - Golding & Golding, A PLC

Golding & Golding: Our International Tax Lawyers practice exclusively in the area of IRS Offshore & Voluntary Disclosure. We represent clients in 70 different countries. Managing Partner, Sean M. Golding, JD, LL.M., EA and his team have represented thousands of clients in all aspects of IRS offshore disclosure and compliance during his 20-year career as an Attorney. Mr. Golding's articles have been referenced in such publications as the Washington Post, Forbes, Nolo and various Law Journals nationwide.

Sean holds a Master's in Tax Law from one of the top Tax LL.M. programs in the country at the University of Denver, and has also earned the prestigious Enrolled Agent credential. Mr. Golding is also a Board Certified Tax Law Specialist Attorney (A designation earned by Less than 1% of Attorneys nationwide.)
International Tax Lawyers - Golding & Golding, A PLC