The IRS has launched a new automatic penalty relief program. However, taxpayers will still need to apply for penalty relief in some cases, and those who are not eligible will need to consider other alternatives. In some cases, this will involve submitting a voluntary disclosure.

Failure to timely disclose foreign bank accounts to the federal government can lead to steep penalties—including criminal penalties in some cases. As a result, taxpayers who are behind on their foreign bank account disclosures should work with experienced tax counsel to come into compliance before the IRS opens an audit or investigation.

Failing to disclose an individual or corporate taxpayer’s foreign bank accounts to the federal government can have serious consequences. Not only can noncompliance lead to substantial fines, but it can also lead to federal prison time in some cases. With DOJ and IRS FBAR investigations on the rise, taxpayers need to prioritize compliance in 2026.

The IRS has established a new Automatic Exemption from Penalty (AEP) program that will streamline relief for eligible taxpayers. For those who are not eligible, nothing is changing. In all cases, delinquent taxpayers need to make informed decisions about coming into compliance, as IRS audits and investigations can lead to serious consequences.

Criminal tax fraud investigations can lead to various charges under federal law. When targeted in these investigations, taxpayers must execute informed, comprehensive, and cohesive defense strategies that take into account all of the allegations (and potential allegations) involved. This starts with engaging an experienced New Jersey criminal tax lawyer promptly.