On Feb. 18, 2009, the Department of Justice entered into a Deferred Prosecution Agreement with UBS AG. Since that time, the government has aggressively pursued taxpayers who maintained undisclosed offshore accounts. While tens of thousands of taxpayers have cured their historical non-compliance through Offshore Voluntary Disclosure Programs or Initiatives offered by the IRS, approximately 100 taxpayers who failed to make timely voluntary disclosures were subject to criminal investigation and prosecution, with the associated exposure to loss of liberty and financial penalties. A second, more fortunate, subset of the non-compliant taxpayers who did not participate in a voluntary disclosure program were subjected to IRS audits, which carried the potential for substantial civil penalties without the risk of incarceration.