On February 8, 2011, the Internal Revenue Service (the “IRS”) announced a second, special voluntary disclosure initiative for taxpayers with unreported income from foreign accounts or assets during the 2003-2010 taxable years. The new initiative, which is intended to enable taxpayers with undisclosed foreign income to become compliant with the U.S. tax system, will only be available through August 31, 2011. The IRS warns that taxpayers who decide not to participate in the new initiative face a high risk of detection by the IRS, the imposition of substantial civil penalties, and an increased probability of criminal prosecution.