The Internal Revenue Service plans to introduce a revised voluntary disclosure program before December 2026 covering cryptocurrency tax violations. Speaking at the UCLA Extension Tax Controversy Conference, IRS Criminal Investigation Chief Jarod Koopman stated that digital assets will use general tax compliance channels. The overhauled framework targets resolving cases within 120 days, offering substantially lower penalties alongside payment plans and offers in compromise.
Structure of the voluntary disclosure program
- ▪The Internal Revenue Service decided to handle digital asset disclosures through its general voluntary disclosure program rather than creating a separate channel for cryptocurrency
- ▪Internal Revenue Service Criminal Investigation Chief Jarod Koopman announced plans to introduce a revised version of the IRS's voluntary disclosure program covering digital assets before December 2026
- ▪The Internal Revenue Service's current voluntary disclosure program primarily targets taxpayers whose willful failure to comply with tax laws exposes them to potential criminal prosecution
Case resolution timelines
- ▪The Internal Revenue Service's existing voluntary disclosure resolution process can take a year or longer for applicants to complete
- ▪The Internal Revenue Service aims to resolve tax disclosure cases within 120 days after taxpayers submit the required completion documents under the IRS's revamped voluntary disclosure program
Digital Asset Tax Certainty Act
- ▪The United States House Ways and Means Committee approved the Digital Asset Tax Certainty Act in September 2026
- ▪Section 502 of the proposed Digital Asset Tax Certainty Act would establish a statutory voluntary disclosure program tailored for crypto taxpayers who made unintentional reporting errors
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