Terry Segal (Duane Morris, Boston) & Michael Mustokoff (Duane Morris, Philadelphia) have published Advice for Americans with Undisclosed Bank Accounts at UBS and Other Foreign Banks as IRS Lifts Cloak of Swiss Bank Secrecy (Wealth Strategies Journal):
In our view, the UBS case is just the tip of the iceberg in the IRS's attempt to force American taxpayers to disclose their foreign accounts in not only Switzerland but other countries, and bring these taxpayers back into compliance regarding their offshore holdings. According, we believe that American taxpayers with non-UBS undisclosed Swiss accounts and non-Swiss undisclosed foreign bank accounts would also be well advised to attempt to participate in the IRS's voluntary disclosure program.



