The Future of Voluntary Disclosure

11 Pages Posted: 4 Sep 2018 Last revised: 1 Oct 2018

See all articles by Noam Noked

Noam Noked

The Chinese University of Hong Kong (CUHK) - Faculty of Law

Date Written: August 6, 2018


This article calls for the IRS to adopt permanent voluntary disclosure procedures that incorporate specific features of the latest offshore voluntary disclosure program and correct some of its flaws. If the IRS does not provide new voluntary disclosure procedures for willful noncompliance, taxpayers will face uncertain penalties under the so-called quiet disclosures and the traditional voluntary disclosure practice outlined in the Internal Revenue Manual. That uncertainty - and the potential for inconsistent treatment of similarly situated taxpayers - would increase the costs of becoming compliant and ultimately discourage taxpayers from making voluntary disclosures.

Keywords: Voluntary Disclosure, Tax Amnesty, OVDP, Offshore Voluntary Disclosure Program, Tax Evasion, Willful Noncompliance, IRS

JEL Classification: H26, K34

Suggested Citation

Noked, Noam, The Future of Voluntary Disclosure (August 6, 2018). 160 Tax Notes 783 (2018). Available at SSRN:

Noam Noked (Contact Author)

The Chinese University of Hong Kong (CUHK) - Faculty of Law ( email )

6/F, Lee Shau Kee Building
Shatin, New Territories
Kowloon, Sha Tin
Hong Kong

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