When a taxpayer comes to us to initiate a voluntary disclosure, it's important that we quickly gather their banking information so we know exactly how much previously unreported income they now need to report. And we need to identify them to the Internal Revenue Service as quickly as possible to lay down our marker that they want to come in and make a voluntary disclosure.
The system that ultimately developed in the U.S. special program, which provided an expedited way back into the system for these people, was quite effective. Basically, there was a pre-clearance process where we would provide the name of a client to the Internal Revenue Service. We would ask if a disclosure would be considered timely, and then they would check their files over a period of a week or two and get back to us and say, “Yes, it will be considered timely.”
That was essentially the protection that a client needed, to know that he wouldn't be prosecuted. Once they make a timely disclosure, the rest of the disclosure is simply ensuring that it is truthful and complete, and that they pay their liability.
As an immediate step, I would suggest you give people a risk-free path into the system.