The Recorder, Amnesty's Allure:

The Justice Department's success in cracking the secrecy of Swiss bank UBS has opened up a whole new arena for lawyers handling tax disputes. The lower-penalty voluntary disclosure program the IRS ran between March and October prompted thousands of U.S. taxpayers with foreign accounts to come out of the woodwork — more than anyone had dreamed. In mid-November, the government announced that more than 14,700 taxpayers had come forward, dwarfing the number of those who'd done so in 2008. …

Though the deadline to fess up under the special program has passed, California tax lawyers say they're still getting calls. People worried their foreign bank will hand their records over to the IRS continue to look for guidance on how to minimize penalties and avoid criminal charges. …

Scott Frewing, a tax controversy partner in the Palo Alto office of Baker & McKenzie, says he's always done one or two formal voluntary disclosures a year to the criminal investigation side of the IRS. But things have picked up since the UBS investigation first made headlines last fall. Now Frewing, whose hourly rate is $720, is working with about 140 clients on the West Coast alone. Most of them have offshore accounts in Europe, but a growing number are linked to accounts in Asia. He suspects the next announcement will be about an agreement between the government and a bank in Hong Kong or Singapore. "I know there are agents here working on those issues," he said.

Baker & McKenzie has shifted resources from other practices to handle the work. A year ago, Frewing said, he was the only lawyer in the Bay Area working on offshore accounts. Now, up to eight lawyers devote a significant portion of their time to them, including tax litigators and lawyers versed in trusts and closely held corporations in an international setting.