Sponsor
Aaron Bean
Representative · R-FL
Representative · R-FL
The bill offers a limited, time‑bound amnesty-like program allowing taxpayers to resolve prior unreported digital‑asset tax issues and avoid certain civil and criminal penalties if they fully disclose and pay, but it imposes substantial immediate costs, leaves undisclosed wrongdoing exposed to prosecution, and includes tight deadlines and confidentiality uncertainties.
Taxpayers who previously failed to report digital‑asset transactions and who timely participate can avoid criminal prosecution for those disclosed violations under the program.
Eligible participants who comply and pay the required program penalty receive waivers of accuracy‑related and fraud civil penalties (e.g., sections 6662/6663), reducing additional tax penalty exposure.
Establishes a clear, time‑limited administrative pathway to resolve prior digital‑asset tax issues (file amended returns, make payments by deadlines) and gives Treasury limited flexibility to waive penalties for reasonable cause or in the interests of justice, simplifying and centralizing resolution.
Participants must pay substantial immediate costs — significant penalty rates (typically 25–50% or higher) plus full tax and interest — which can be a large, up‑front financial burden.
Criminal protection is limited to violations that are actually disclosed under the program; undisclosed or fraudulent conduct remains prosecutable, so participants may still face criminal exposure.
Strict deadlines, certification requirements, and enhanced penalties for amended returns filed after 12 months may disadvantage taxpayers who are slower to learn about or comply with the program (e.g., low‑income, less‑sophisticated filers).
Based on analysis of 2 sections of legislative text.
Creates a Treasury voluntary disclosure program letting eligible taxpayers amend returns, pay tax/interest and a digital-assets penalty in exchange for limited civil-penalty waivers and constrained criminal referrals.
Official title: To establish the Digital Assets Voluntary Disclosure Program.
Introduced June 8, 2026 by Aaron Bean · Last progress June 8, 2026
Creates a Treasury-run Digital Assets Voluntary Disclosure Program that lets eligible taxpayers fix prior failures to report or comply with tax rules for digital assets. The program requires applicants to file amended returns, pay owed tax and interest (or enter an installment agreement), and pay a specified digital-assets-violation penalty; in exchange the IRS will waive certain civil penalties and generally will not use properly disclosed information to refer the taxpayer for criminal prosecution for those disclosed violations. The Secretary of the Treasury must establish the program within 12 months of enactment and set program rules. The law distinguishes uncertified and certified eligible taxpayers, defines eligibility and remedial steps, and sets limits on IRS penalty assessments and criminal referrals for disclosed digital asset violations when the program's remedial requirements are satisfied.