IRS Removes Willfulness Checkbox from Form 14457, Easing Path for Voluntary Disclosures
In a significant policy shift, the IRS has revised Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the cornerstone of its Voluntary Disclosure Practice (VDP), by removing the controversial “willfulness checkbox.” This change, effective with the July 2025 version of the form, marks a major win for taxpayers and tax professionals who have long criticized the checkbox as a deterrent to participation in the program. In short, the removal of the willfulness checkbox from the updated VDP form incentivizes taxpayers who were previously wary about admitting that they had willfully failed to disclose information to the IRS to – after consultation with their advisors and attorneys – reconsider whether entering VDP is a viable and wise option in their situation. Background: The Role of Form 14457 Form 14457 is used by taxpayers seeking to voluntarily disclose previously unreported income or tax noncompliance in order to avoid criminal prosecution. The form op...