What Are the Options for Submitting a Streamlined Voluntary Disclosure to the IRS in 2026?

The IRS’ streamlined voluntary disclosure programs provide taxpayers with opportunities to proactively resolve federal tax issues before they result in an audit or investigation. For 2026, the IRS is continuing its two major voluntary disclosure programs offered in previous years. Learn what taxpayers need to know before they submit a streamlined voluntary disclosure from New Jersey international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group:

5 Key Facts About the IRS’ Streamlined Voluntary Disclosure Programs in 2026

Taxpayers may be eligible to participate in each of the IRS’ streamlined voluntary disclosure programs in very different sets of circumstances. Each of these programs has its own unique set of eligibility requirements, filing requirements, and resolution requirements. Here is an introduction to what taxpayers in New Jersey need to know:

1. Covered Tax Law Violations

The two streamlined voluntary disclosure programs that are available in 2026 are: (i) the IRS’ streamlined filing compliance procedures; and, (ii) IRS CI’s Voluntary Disclosure Practice. While IRS CI accepts voluntary disclosures involving all types of federal tax law violations, the IRS’ streamlined filing compliance procedures apply specifically to violations of taxpayers’ foreign financial asset disclosure obligations.

2. Non-Willful vs. Willful Violations

Under the IRS’ streamlined filing compliance procedures, taxpayers can resolve non-willful violations that might otherwise lead to a high-stakes civil tax audit. Under the IRS CI’s Voluntary Disclosure Practice, taxpayers can resolve willful violations that carry the risk for criminal prosecution under the Internal Revenue Code and other applicable laws.

3. Eligibility and Filing Requirements

The IRS’ streamlined filing compliance procedures and IRS CI’s Voluntary Disclosure Practice have other eligibility and filing requirements as well. Under the IRS’ streamlined filing compliance procedures, there are different requirements for taxpayers living in the U.S. and abroad. Under the IRS CI’s Voluntary Disclosure Practice, all taxpayers must obtain “preclearance” from the IRS CI before continuing under the program.

4. Financial Obligations for Taxpayers

Under both of the IRS’ streamlined voluntary disclosure programs, taxpayers must generally be prepared to pay what they owe—including applicable interest and penalties. If necessary, taxpayers may be able to enter into a full-pay installment agreement with the IRS as part of the process.

5. Implications Going Forward

While submitting a voluntary disclosure under either program can mitigate taxpayers’ risk going forward, the IRS does not make any guarantees. With regard to streamlined filings, the IRS states, “the streamlined filing process will not culminate in the signing of a closing agreement with the IRS.” With regard to IRS CI’s Voluntary Disclosure Practice, the IRS states, “[a] voluntary disclosure will not automatically guarantee immunity from prosecution . . . [but] may result in prosecution not being recommended.”

Schedule a Confidential Consultation with New Jersey International Tax Attorney Kevin E. Thorn

If you need more information about the options for submitting a streamlined voluntary disclosure to the IRS in 2026, we invite you to get in touch. To schedule a confidential consultation with New Jersey international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, please call 201-842-7696 or contact us online today.