FBARs and not-yet-reported offshore income: penalties and practitioners' issues

This item considers (1) options available for the client that did not disclose under the IRS's voluntary disclosure program, which ended October 15, 2009; (2) practitioners' responsibilities, including tax organizers and engagement letters; and (3) items suspended and/or extended to the June 2010 due date. Is it too late to initiate a voluntary disclosure under the IRS program for unreported offshore income and foreign bank and financial accounts? If a client asks for a recommendation, what are the options? As of this writing, the IRS has released little in the way of new guidance.