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I am surprised the New York Times did not mention the IRS Voluntary Disclosure Program for Offshore Assets. According to the IRS, "voluntary programs have resulted in more than 45,000 voluntary disclosures from individuals who have paid about $6.5 billion in back taxes, interest and penalties." (See IRS June 6, 2014 Press Release available here

There is a good chance that some of the tax-payers tax structures analyzed in preparation for this article came into compliance through it. To make matters worse, the NY Times reported on it numerous times since its first incineration in 2009— with the latest Jan. 10 2012 on page B6, available at — which only makes this passing mention of investigations by the Department of the Treasury that much more disappointing.