Revenue voluntary disclosure

AN ACT Relating to improving tax administration and generating 1
additional revenues by waiving penalties and interest by creating a 2
voluntary disclosure program within the department of revenue; adding 3
a new section to chapter 82.32 RCW; creating a new section; providing 4
an effective date; and declaring an emergency. 5
BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF WASHINGTON:6
NEW SECTION. Sec. 1. The legislature intends to create a formal 7
voluntary disclosure program to encourage more taxpayers to register 8
with the department of revenue and pay taxes in perpetuity.9
Furthermore, the legislature finds that the last tax amnesty 10
program in Washington state, between February 1, 2011, and April 30, 11
2011, generated $345,800,000 and over 5,000 taxpayers were granted 12
amnesty. By waiving penalties and interest for a limited period of 13
time, the legislature intends to accelerate the number of taxpayers 14
that participate in the voluntary disclosure program, similar to the 15
amnesty program in fiscal year 2011. 16
NEW SECTION. Sec. 2. A new section is added to chapter 82.32 17
RCW to read as follows: 18
(1) The department shall enter into an agreement with a voluntary 19
registrant in which the department waives any portion of penalties 20
S-2580.2
SENATE BILL 5806
State of Washington 69th Legislature 2025 Regular Session
By Senators Muzzall and Gildon
p. 1 SB 5806
that would otherwise be imposed on the voluntary registrant under RCW 1
82.32.090 (1), (2), or (4), for tax liability incurred while the 2
person was not registered as required by RCW 82.32.030.3
(2) For the purposes of this section, "voluntary registrant" 4
means any person who: 5
(a) Engages in any taxable activity that requires registration 6
under RCW 82.32.030, while unregistered; 7
(b) Submits an application for a registration certificate under 8
RCW 82.32.030 prior to any department contact with the person;9
(c) Has not engaged in fraud, evasion, or misrepresentation in 10
reporting tax liabilities, with regard to any tax administered by the 11
department under this chapter; 12
(d) Has disclosed all relevant taxable activity to the 13
department; and 14
(e) Attests, under penalty of perjury, in a form and manner as 15
required by the department, that the person meets the requirements of 16
(a) through (d) of this subsection. 17
(3)(a) For the purposes of qualifying as a voluntary registrant 18
under subsection (2) of this section, the department is deemed to 19
have contacted the person, if, during the current or preceding four 20
calendar years: 21
(i) The contact is for tax enforcement purposes;22
(ii) The contact is clearly directed to that person; and23
(iii) The contact requests the person to take some action in 24
response to the contact. 25
(4) If the department determines that facts differ materially 26
from what the taxpayer originally represented to the department to 27
qualify as a voluntary registrant, the penalty and interest relief 28
granted under subsection (1) of this section may be rescinded, in 29
whole or in part, at the discretion of the department.30
(5) Subsection (1) of this section does not relieve any person 31
from liability for state and local sales taxes that the person 32
collected from buyers but did not remit to the department.33
(6) Nothing in this section may be construed as authorizing the 34
refund of state and local sales and use taxes properly paid before 35
July 1, 2025. 36
(7) For any qualifying voluntary registrant who submits a 37
voluntary disclosure application after July 1, 2025, and prior to 38
September 30, 2025, the department shall waive all penalties and 39
interest that would otherwise be imposed on the voluntary registrant 40
p. 2 SB 5806
under RCW 82.32.090 (1), (2), or (4), for tax liability incurred 1
while the person was not registered as required by RCW 82.32.030.2
NEW SECTION. Sec. 3. This act is necessary for the immediate 3
preservation of the public peace, health, or safety, or support of 4
the state government and its existing public institutions, and takes 5
effect July 1, 2025.6
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p. 3 SB 5806