“A much larger number of what the IRS calls ‘recalcitrant’ account-holders chose another route. Instead of entering a voluntary disclosure program, they simply started reporting their foreign accounts, without paying penalties or interest. Such taxpayers avoid paying any delinquent taxes, interest, or penalties, unless audited. Evidence of an explosion in quiet disclosures comes from the fact the number of people filing FBAR forms nearly doubled from 281,000 in 2007 to 516,000 in 2010. The agency has urged the IRS to examine closely these first-time filers for disclosure violations in earlier years. And, the IRS has promised to do just that.”
http://www.nestmann.com/irs-idenitying-offshore-tax-cheating/
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