Content Provider
Middlebanner ggu
Handout Materials
Presentation Slides
Additional Materials
Form 14457
Webinar Technical FAQs
Cpece webinars
IRS Voluntary Disclosure: Where Are We Now?


Cost Free
Presentation Length 1.0 hour

Recorded DateJune 30, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

This special program will be presented by the three tax attorneys who are the Voluntary Disclosure subcommittee for the American Bar Association's Tax Section's Criminal Penalties committee.

Attorneys Eric Green, Laura Gavioli, and John Nail will update you on where the IRS stands on voluntary disclosure for domestic and foreign issues and how best to use the program to save your client from their past misdeeds. They will also cover topics with the IRS disclosure form 14457 and issues you need to address with the client before filing!

Learning Objectives: 

  • Determine where the IRS stands on voluntary disclosure for both domestic and foreign issues

  • Identify how best to make use of the program to save your client from past misdeeds

  • Review issues with the IRS disclosure form 14457 and issues that you need to address with the client before filing

Not logged

Eric is a partner in Green & Sklarz LLC, a boutique tax firm with Connecticut and New York offices. The focus of Attorney Eric L. Green's practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service, and state Departments of Revenue Services. His practice also handles probate matters and estate planning for individuals and business owners, and tax planning for closely-held businesses. He is a frequent lecturer on tax topics for CCH, the NAEA, the NATP, the ABA Tax Section, and the Connecticut Society of CPAs. Attorney Green has served as adjunct faculty at the University of Connecticut School of Law. He is the author of The Accountant's Guide to IRS Collection (available, and he is a columnist for CCH's Journal of Practice & Procedure. He is also the founder of The New England IRS Representation Conference. Mr. Green is a contributing author for Advocating for Low-Income Taxpayers: A Clinical Studies Casebook, 3rd Edition, and has also been quoted in The Wall Street Journal, USA Today, Consumer Reports, The Wall Street Journal's Market Watch,, and Before practicing law Attorney Green served as a senior tax consultant for KPMG and Deloitte & Touche. Attorney Green was the 2010 Nolan Fellow of the American Bar Association and has served as Chair of the American Bar Association's Closely Held Businesses Tax Committee. Attorney Green is the current Chair of the Executive Committee of the Connecticut Bar Association's Tax Section. Eric is a Fellow of the American College of Tax Counsel ("ACTC") and a Connecticut, Massachusetts, New York, and American Bar Association member. He is admitted to practice in Massachusetts, New York, and Connecticut Superior Courts, as well as the United States Tax Court, the Federal Court of Claims, and the Federal District Court for Connecticut. Attorney Green received his Bachelor of Business Administration degree in Accounting with a minor in International Business from Hofstra University and is an honor graduate from New England School of Law. He earned a Masters of Laws in Taxation (LL.M.) from Boston University School of Law.

User-added image


John is an associate in the Tax Controversy and Litigation section in Atlanta, Georgia. His practice focuses on representing clients in all levels of their matters with the IRS, from examination and appeals to litigation in the U.S. Tax Court and Federal District Court.

John has significant experience that allows him to effectively counsel clients in tax matters. Some areas in which he has assisted clients include disallowed deductions for charitable contributions, executive compensation, and bad business debts; employment tax compliance; state sales and use tax audits; and collection activities. John also has experience counseling high net worth individuals and corporate clients on tax, estate, and business planning issues.


Laura L. Gavioli is a partner in the Federal & International Tax Group and a member of the Tax Controversy Team. As an experienced first-chair trial lawyer, Laura is known for achieving practical, client-driven goals when defending against IRS inquiries. She has represented clients involved in some of the largest white-collar criminal tax evasion cases ever brought in the U.S. and advises clients on the IRS Whistleblower Program. In addition, she attained taxpayer victories in civil tax cases in U.S. Tax Court and federal district courts, eliminating IRS penalties.

Laura focuses her practice on the business dealings and asset holdings of U.S. taxpayers abroad. She has extensive knowledge of the IRS’s international exchange-of-information techniques, including treaty requests and other methods of cross-border cooperation among taxing authorities.

Laura has an aptitude for clearly explaining highly technical, complex tax issues. She has litigated numerous cases addressing jurisdictional questions under taxation statutes and setting precedent for statutes of limitations. Laura also advocated for multinational enterprises, relying on plain-language readings of taxation statutes to combat unjustified IRS positions, including those taken in regulations under the Tax Cuts and Jobs Act.

Chambers USA: America’s Leading Lawyers for Business has recognized her in Tax: Litigation.

About Our Presenter

The Tax Rep LLC is an online member-driven organization whose mission is to enhance all of its members IRS representation practices by sharing experiences, representation techniques and marketing strategies with each other.