There's a debate in the United States over just how successful this IRS program was. I happen to be of the view that, notwithstanding some of the procedural and bureaucratic difficulties, from a macro perspective it was enormously successful.
Over 30 years of practice, before the program, I may have advised 100 to 150 clients to make voluntary disclosures. Our law firm had 400 cases within the course of about seven months: 15,000 people came forward. I think the average size of the accounts that were disclosed in our office was probably somewhere in the $3 million to $5 million range. These are assets that are coming back into the system. They'll be taxed every year in the United States. Now they're taxed again when you die.
So I think the system--for some of its flaws--that the IRS implemented in 2009 was an extraordinary success.