In this article, Steve Dixon discusses the aftermath of the UBS voluntary disclosure program. The IRS received an unprecedented amount of information about undisclosed offshore accounts in 2009. At this point, most of that information has come from the nearly 15,000 account owners or beneficiaries who came forward under the IRS’s Voluntary Disclosure program. But it appears that the IRS will soon receive more account information under its treaty agreement with UBS and the Swiss government. This influx of information about unreported accounts raises questions of whether DOJ will prosecute anyone who came forward under the IRS’s Voluntary Disclosure initiative and how hard DOJ will come down on those UBS accountholders who did not voluntarily disclose.