I got a call this afternoon about the UBS situation and the expected approval of the UBS-IRS agreement by the Swiss Parliament in June. The question was simply “How long do you have after the Parliament approves the UBS agreement before the IRS gets the names of U.S. taxpayers?”
My answer: If the IRS has any brains at all, they will have all of this information within a couple of hours of Parliamentary approval.
If you wait until the day of the vote in Berne, you won’t have enough time to get to the IRS with a voluntary disclosure. Now would be a good time to act. Now.
I repeat the advice of the esteemed Rufus Rhoades: it’s only money. Or, my corollary to that advice: don’t make a money problem into a jail problem.