2026 IRS Streamlined Voluntary Disclosure Programs: Why It’s Important for Taxpayers to Choose Wisely

Taxpayers who are behind on their federal filing and payment obligations will want to come into compliance before the IRS opens an audit or investigation. Facing an audit or investigation presents substantial risks—especially when taxpayers know they haven’t fully complied with the requirements. In many cases, coming into compliance will involve utilizing one of the IRS’ streamlined voluntary disclosure programs. Learn more from Virginia international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group:

The IRS is Offering Two Streamlined Voluntary Disclosure Programs in 2026

As it has in years past, the IRS is offering two streamlined voluntary disclosure programs in 2026. However, these programs are very different from one another. This makes it imperative for taxpayers to choose wisely—as submitting the wrong type of voluntary disclosure could do more harm than good.

1. The IRS’ Streamlined Filing Compliance Procedures

The IRS’ streamlined filing compliance procedures are available to taxpayers who need to remedy non-willful foreign financial asset disclosure violations. U.S. taxpayers have obligations to disclose qualifying foreign financial assets (including offshore bank accounts) under the Bank Secrecy Act (BSA) and the Foreign Account Tax Compliance Act (FATCA). Those who have inadvertently failed to comply with these obligations may be eligible to come into compliance through a streamlined filing.

2. IRS CI’s Voluntary Disclosure Practice

IRS CI’s Voluntary Disclosure Practice serves as a means for taxpayers to resolve willful tax law violations without facing criminal prosecution. While IRS CI makes clear that submitting a voluntary disclosure does not guarantee immunity from prosecution, “a voluntary disclosure may result in prosecution not being recommended.” While IRS CI’s Voluntary Disclosure Practice applies to all types of willful tax law violations, strict eligibility criteria apply, and, in all scenarios, taxpayers need to be extremely careful about disclosing willful violations to the federal government.

Which Option Should U.S. Taxpayers Choose in 2026?

So, which option should U.S. taxpayers choose in 2026? The answer to this question depends on each individual taxpayer’s circumstances. The question of willfulness is a key issue, as falsely certifying non-willfulness under the IRS’ streamlined filing compliance procedures can have serious consequences.

But this is just one of many issues. To make informed and strategic decisions, taxpayers must give due consideration to all pertinent issues—and they must do so before the IRS launches an audit or investigation. Under both of the IRS’ streamlined voluntary disclosure programs, to qualify as “voluntary,” a disclosure must be made before the IRS opens a formal inquiry.

Discuss Your Options with Virginia International Tax Attorney Kevin E. Thorn

If you need more information about your options for proactively resolving a federal tax issue with the IRS in 2026, we encourage you to contact us promptly. To discuss your options with Virginia international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, in confidence, call 703-752-3752 or tell us how we can contact you online now.