I just talked to someone at the IRS office in Philadelphia about some voluntary disclosure client matters. I have a pipeline of these things going right now. All the cool kids are turning themselves into the IRS, reporting their offshore bank accounts, and paying their taxes!
Anyway, there isn’t much guidance in this area at the moment. The gentleman at the IRS said they are about to publish a second FAQ which will answer a lot more questions. So stand by. As soon as I get a copy I will link to it.