Disclosure to the IRS through the IRS Amnesty Program must occur before the U.S. Taxpayer is contacted by the IRS.

"The IRS on September 21 announced it is extending by several weeks - from September 23 until October 15 - the filing deadline for taxpayers with offshore accounts who want to take advantage of the Service's special voluntary disclosure program."

Kevin Thorn of Thorn Law Group states that taxpayers with undisclosed foreign accounts should take careful notice of the IRS’s commitment of resources to a long-term strategy for pursuing unreported income and assets kept in undisclosed offshore accounts.