IRS Form 14457
Form 14457: The IRS has developed a form used for Taxpayers in the U.S. or abroad for making a voluntary disclosure disclosure request. The IRS Form 14457 is not used to make all ts will now be made on form 14457.
What is a 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
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:
What Type of Voluntary Disclosure Application 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
- ZIP Code
- Passport information
Tax Representative Information
The IRS wants information regarding your representative. This Information includes:
- Copier form 2848 (Power of attorney)
- Telephone number
- Fax Number
- Street address
- ZIP Code
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.
Golding & Golding: About Our International Tax Law Firm
Golding & Golding specializes exclusively in international tax, and specifically IRS offshore disclosure.
We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our attorneys have worked with thousands of clients on offshore disclosure matters, including FATCA & FBAR.
Each case is led by a Board-Certified Tax Law Specialist with 20 years of experience, and the entire matter (tax and legal) is handled by our team, in-house.
*Please beware of copycat tax and law firms misleading the public about their credentials and experience.
Less than 1% of Tax Attorneys Nationwide Are Certified Specialists
Sean M. Golding is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.
Recent Golding & Golding Case Highlights
- We represented a client in an 8-figure disclosure that spanned 7 countries.
- We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
- We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
- We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
- We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.
How to Hire Experienced Offshore Counsel
Generally, experienced attorneys in this field will have all the following credentials/experience:
- 20-years experience as a practicing attorney
- Extensive litigation, high-stakes audit and trial experience
- Board Certified Tax Law Specialist credential
- Master’s of Tax Law (LL.M.)
- Dually Licensed as an EA (Enrolled Agent) or CPA
Interested in Learning More about Golding & Golding?
No matter where in the world you reside, our international tax team can get you IRS offshore compliant.
Golding & Golding specializes in FBAR and FATCA. Contact our firm today for assistance with getting compliant.