The voluntary disclosure program which allows US taxpayers to avoid criminal prosecution for not reporting foreign accounts ends on Thursday. No, you’re not reading an old post. The amnesty deadline was extended last month from September 23 to Thursday, October 15.

How successful is the program? It’s estimated that between 3,000 and 4,000 taxpayers have made disclosures in 2009. In 2008, there were fewer than 100 such disclosures.

Good news for the IRS – and for taxpayers. Once the deadline passes, all bets are off. Don’t be surprised to see a wave of prosecutions follow.

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Kelly Erb is a tax attorney, tax writer and podcaster.


  1. Completely agree with you on the “all bets are off” comment. This extension never sounded like generosity on the Government’s part. It sounded like the perfect way to preempt “reasonable cause” and the “uncertainty defense.” And good luck trying to claim “extenuating circumstances.” By providing the extension the Government comes out looking magnanimous for giving the wayward additional time to file while it gets ready to pounce on the noncompliant.

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