The IRS recently announced changes to its Form 14457, “Voluntary Disclosure Practice Preclearance and Application,” which allows taxpayers to apply to the IRS in an attempt to limit criminal exposure by disclosing past noncompliance and paying past taxes, interest and penalties. The new form includes several revisions that demonstrate a stricter approach towards taxpayers wanting to voluntarily disclose past tax-related misconduct, including: an admission of willfulness, a more detailed narrative requirement, a shorter time to prepare documents, and mandatory full payment. Taxpayers should consult with counsel to examine any increased risks associated with filing the revised form.