An additional 3,000 taxpayers came forward after that program ended, and 12,000 more declared accounts this year under the 2011 program, which had a deadline of Sept. 9 and less generous terms for taxpayers than the previous version. Shulman said the 2011 program has yielded $500 million so far, and he expects that to increase because the total so far doesn't include many penalties.
"That's more than I expected in the second round," said Mark Matthews, a Washington-based tax attorney at Morgan Lewis & Bockius LLP. Overall, "a lot of practitioners think this was one of the most successful tax compliance actions in history," said Matthews, a former IRS deputy commissioner.
Matthews said he'd like the IRS to issue guidance now that the disclosure initiative has ended.
"What do we do now?" Matthews asked. Those who have come forward, he said, are "still only a fraction of the people who have these accounts."
Some people didn't come forward because they were comparing the risk of getting caught with the penalties they would owe under the program.
Richard Sapinski, a lawyer at Sills, Cummis & Gross P.C. in Newark, New Jersey, said he doubts the IRS will offer another partial amnesty because that would undermine tax compliance.
"I think they probably would be very hesitant to have a third program," Sapinski said. "It would be like catching a bus. You miss one and you wait for the next one."