AN ACT Relating to codifying the voluntary disclosure tax program and authorizing temporary tax amnesty;
SB 6348 codifies Washington’s voluntary disclosure tax program and creates a temporary tax amnesty/penalty waiver process for certain taxpayers. The bill directs the Department of Revenue to implement a voluntary disclosure program beginning July 1, under which eligible persons, including affiliates and subsidiaries, may come forward to disclose taxable activity, register, and pay taxes due in exchange for waiver of penalties. To qualify, applicants must not have been directly contacted by the department for tax enforcement purposes during the current or prior four calendar years, must not have engaged in fraud or misrepresentation, and must meet other application requirements set by the department.
The bill also establishes a limited amnesty period for unpaid penalties and interest on specified business and occupation, public utility, retail sales, and use tax liabilities that first became due before a stated cutoff date. Eligible taxpayers must file required returns, pay the full tax balance by specified deadlines, and satisfy conditions such as having no prior evasion penalty or related criminal prosecution. The measure further amends tax administration provisions to require or authorize electronic filing and electronic payment in many cases, allows the department to set rules and grant extensions or waivers for good cause, and specifies how payments are applied among taxes, interest, penalties, and fees.
The bill would add new sections to chapter 82 RCW and amend existing tax administration statutes to formalize a voluntary disclosure regime and a temporary amnesty/penalty-relief process. It expands the Department of Revenue’s authority to waive penalties and interest for qualifying taxpayers, sets application and payment deadlines, and preserves the department’s ability to verify reported liabilities and assess underpayments not covered by relief. It also strengthens administrative requirements around electronic filing, electronic payment, extensions, and payment allocation, affecting taxpayers with liabilities under the state’s business, sales, use, and utility tax systems.
The bill’s overall tone is pro-compliance and revenue-collection oriented, with the apparent goal of encouraging taxpayers to self-report and bring outstanding liabilities into the system. Because there are no committee transcripts or recorded votes provided, there is no direct evidence of debate or partisan division in the supplied materials. Based on the text alone, the measure appears designed to be attractive to taxpayers seeking a clean path to compliance while protecting state revenue through full payment of taxes owed.
The main points of contention inherent in the bill are the scope of relief and the eligibility limits. The bill conditions amnesty on full payment of tax, excludes taxpayers with recent department contact, fraud, misrepresentation, prior evasion penalties, or related criminal prosecutions, and bars refund claims or challenges to amounts paid under the program. Another possible point of concern is the department’s broad discretion to set rules, determine good cause for waivers and extensions, and rescind agreements if information is falsified, which may raise questions for taxpayers about predictability and administrative fairness.