The IRS currently is offering the Offshore Voluntary Disclosure Program (“OVDP”) that began in January 2012. However, the IRS has reserved the right to end the program at any time. For that reason, we urge you to review the IRS OVDP page (see http://www.irs.gov/uac/2012-Offshore-Voluntary-Disclosure-Program) as well as the Frequently Asked Questions page (see http://www.irs.gov/Individuals/International-Taxpayers/Offshore-Voluntary-Disclosure-Program-Frequently-Asked-Questions-and-Answers-2012-Revised), and review the pages to determine whether or not you are comfortable in dealing with the requirements/issues noted on the IRS website. The potential penalties are substantial and will ultimately depend on each taxpayer’s specific circumstances. We can say from experience that the issues involved in reporting foreign activities are often highly technical. Bottom line, it is definitely possible to represent clients, but unless you are very familiar with areas such as Controlled Foreign Corporations, Passive Foreign Investment Companies, Source of Income (i.e., foreign vs. US), Foreign Currency gain/loss characterization, and the like, it is probably best to seek qualified outside help.