Are you looking for an IRS voluntary disclosure lawyer in Hanover, MD?
At Crepeau Mourges, we have built our IRS voluntary disclosure practice on over 15 years of advisory experience representing clients in Hanover and throughout Maryland.
If you have unreported income, undisclosed foreign accounts, or unfiled tax returns and are concerned about potential criminal liability, coming forward through the IRS Voluntary Disclosure Practice may be your best option. At Crepeau Mourges, our attorneys guide individuals and businesses through the voluntary disclosure process, working to resolve years of noncompliance while minimizing exposure to prosecution. Our Hanover, MD IRS voluntary disclosure lawyer can evaluate your situation, determine the right disclosure path, and manage the process from preclearance through resolution. Schedule a free consultation to discuss your case.
IRS Voluntary Disclosure Lawyer Hanover, MD
An IRS voluntary disclosure is a formal process administered by IRS Criminal Investigation that allows taxpayers with criminal tax exposure to come forward, report their noncompliance, and potentially avoid prosecution. It is not the same as filing an amended return. The process requires a preclearance application, full financial disclosure, and cooperation with the IRS in determining the correct tax liability.
The National Taxpayer Advocate reported that IRS Criminal Investigation completed only 161 voluntary disclosure cases in the nearly six years between September 2018 and August 2024. Those low numbers reflect how few taxpayers use the program and how high the stakes are for those who do. For taxpayers in Hanover, MD considering a voluntary disclosure, having an experienced attorney manage the process is essential. It is the difference between resolving your tax issues and making them worse.
Types of IRS Voluntary Disclosure Cases We Handle in Hanover
Voluntary disclosure applies to a range of noncompliance situations. At Crepeau Mourges, we represent clients in Hanover, MD across every category of disclosure the IRS accepts.
- FBAR. U.S. taxpayers who hold foreign bank accounts with an aggregate value exceeding $10,000 must file an annual Report of Foreign Bank and Financial Accounts. Willful failure to file carries severe civil and criminal penalties. Voluntary disclosure can resolve FBAR noncompliance before the IRS discovers it.
- FATCA. The Foreign Account Tax Compliance Act requires disclosure of foreign financial assets on Form 8938. Noncompliance with FATCA reporting requirements can trigger substantial penalties and potential criminal referral.
- Unreported foreign income. Income earned from foreign sources, including investment returns, rental income, and business profits, must be reported on U.S. tax returns. Taxpayers who have failed to report this income for multiple years face compounding liability.
- Delinquent international information returns. Forms 5471, 3520, 3520-A, 8865, and other international information returns carry steep per-return penalties when filed late or not at all. Voluntary disclosure can address multiple years of missing filings.
- IRS criminal tax investigation. Taxpayers who believe their noncompliance may rise to the level of a criminal violation can use voluntary disclosure to get ahead of a potential investigation. The program does not guarantee immunity, but the IRS has a longstanding practice of not prosecuting taxpayers who make timely, truthful disclosures.
- Streamlined filing compliance. For taxpayers whose failure to report foreign financial assets and pay tax was non-willful, the IRS offers streamlined compliance procedures as an alternative to the full voluntary disclosure process. This path involves reduced penalties and no preclearance requirement.
- International tax planning. After a disclosure is complete, taxpayers need a forward-looking compliance strategy to avoid future violations. We help clients structure their offshore tax compliance obligations going forward.
- ERC voluntary disclosure. Employers who received improper Employee Retention Credits can resolve their liability through a separate ERC voluntary disclosure program. We advise businesses on eligibility and guide them through the correction process.
Why Choose Crepeau Mourges as My IRS Voluntary Disclosure Lawyer in Hanover, MD?
International Tax and Voluntary Disclosure Practice
Brandon N. Mourges co-founded Crepeau Mourges and focuses a significant portion of his practice on voluntary disclosure, offshore compliance, and international tax matters. He earned an LL.M. in Taxation from the University of Baltimore School of Law and a B.S. in Economics from the Wharton School. He is a member of the Federal Bar Association, the American Association of Attorney-CPAs, the Maryland State Bar Association, and the Howard County Bar Association.
Mr. Mourges has been recognized as a Rising Star by Super Lawyers and named to Benchmark Litigation’s “40 & Under Hot List.” He speaks and publishes on tax compliance topics, including cryptocurrency taxes and international reporting obligations, and has been featured by Bloomberg News.
Brian J. Crepeau co-founded the firm and concentrates on federal and state tax controversy. He is admitted to practice in Maryland, Florida, and the United States Tax Court. His background in tax controversy complements the firm’s disclosure work, because voluntary disclosures often involve civil examinations that follow the initial criminal resolution. That combination is what you want from an IRS tax lawyer in Hanover, MD handling a matter this sensitive.
What Is Important To Understand About IRS Voluntary Disclosure Cases?
Penalties, Consequences, and Relief Options for Voluntary Disclosure Cases
The penalty framework for voluntary disclosure cases depends on the type of noncompliance and whether the taxpayer’s conduct was willful. Under the current IRS Voluntary Disclosure Practice, taxpayers who are accepted must generally agree to a six-year disclosure period and pay all taxes, interest, and applicable penalties for those years.
Potential penalties include:
- Civil fraud penalties of up to 75% of the underpayment for the highest-liability year
- Willful FBAR penalties, which can reach $100,000 or 50% of the account balance per violation, whichever is greater
- Accuracy-related penalties for the remaining disclosure years
- Late-filing penalties for delinquent information returns
In December 2025, the IRS announced proposed VDP updates that would streamline the penalty framework. These changes, if finalized, may significantly alter the cost of participating. An IRS voluntary disclosure attorney in Hanover, MD can advise you on the current terms and how proposed revisions may affect your case.
What Are Important Aspects of an IRS Voluntary Disclosure Case?
The most critical element of any voluntary disclosure is timing. A disclosure must be made before the IRS has begun a civil examination, opened a criminal investigation, or received information about the taxpayer from a third party. If the IRS already knows about your noncompliance, the disclosure window has closed.
Other key factors include:
- Whether the conduct was willful or non-willful, which determines whether you qualify for streamlined procedures or must use the full VDP
- The number of years of noncompliance and the total tax exposure involved
- Whether foreign financial accounts, entities, or income are part of the disclosure
- The completeness and accuracy of available financial records
- Whether any third-party enablers, such as foreign banks or offshore advisors, are involved
An experienced voluntary disclosure lawyer should be involved from the outset. A single error in the application can jeopardize the entire process.
What Is the IRS Voluntary Disclosure Case Timeline?
Voluntary disclosure cases typically take 12 to 24 months from start to finish, though complex cases involving multiple foreign accounts or entities can take longer. The process generally follows this sequence:
- Preclearance request. The taxpayer’s attorney submits Form 14457 to IRS Criminal Investigation, requesting confirmation that no investigation is already underway.
- Preclearance granted. If the taxpayer is not already under investigation, CI grants preclearance to proceed.
- Full application. The taxpayer submits a complete disclosure package, including a narrative of the noncompliance, all required tax returns, FBARs, and financial documentation.
- Conditional acceptance. Once accepted, the taxpayer must pay all taxes, penalties, and interest within three months.
- Closing agreement. The IRS and the taxpayer execute a closing agreement that finalizes the terms of the disclosure.
Timing is critical throughout this process. The longer you wait, the higher the risk that the IRS will obtain information about your noncompliance from another source.
What Should You Bring to Your IRS Voluntary Disclosure Consultation?
Voluntary disclosure consultations require more preparation than a typical tax meeting. To the extent you have them, bring:
- Any foreign bank account statements, investment records, and entity formation documents
- U.S. tax returns for the past six to eight years, if filed
- Information about foreign trusts, corporations, partnerships, or other entities in which you hold an interest
- Records of income from foreign sources, including rental, investment, and business income
- Any prior correspondence with the IRS or a tax professional regarding your compliance concerns
Your IRS voluntary disclosure attorney will use this information to determine your eligibility, calculate your potential tax and penalty exposure, and recommend the most effective disclosure path.
Hanover IRS Resources and Federal Court Information
Voluntary disclosure applications for Hanover, MD taxpayers are submitted directly to IRS Criminal Investigation headquarters. The IRS CI Washington, D.C. Field Office, which covers Maryland, oversees investigations and disclosures in the region. If a disclosure leads to a civil examination or contested penalty assessment, proceedings may take place before the U.S. District Court for the District of Maryland, which sits in Baltimore and Greenbelt.
Reach Out to Crepeau Mourges to Schedule a Consultation
If you have undisclosed income, unreported foreign accounts, or unfiled returns and are concerned about criminal exposure, Crepeau Mourges can help you evaluate whether voluntary disclosure is the right path. We offer free consultations for IRS voluntary disclosure matters, and we handle these cases with the discretion they require. The window to act voluntarily closes the moment the IRS learns about your noncompliance from another source. Contact us to schedule a confidential consultation.
