The IRS Offshore Account Voluntary Disclosure Program (the “Program”) is over.  But that does not mean U.S. taxpayers with undisclosed foreign bank accounts should stay in hiding.  In fact, the relative success of the Program makes it imperative for people with still undisclosed accounts to come forward and make a voluntary disclosure.

Now we know how UBS will determine which U.S. clients to turn over to the IRS.

The agreement requires UBS to turn over approximately 4,500 names of US taxpayers with foreign accounts.  However, UBS is not required to turn over any names until AFTER the September 23 deadline for US taxpayers to voluntarily disclose their accounts using the offshore account settlement initiative. 

Obviously, some people believe these are the most egregious cases, what the government would call the most challenged offenders.  However, others believe, these are some of the names of US citizens that were released to the government by UBS in February.