Might be the case! Here was my impression though (based on what I read after the fact): The laws were always on the books but rarely enforced. Only once the UB

Might be the case! Here was my impression though (based on what I read after the fact): The laws were always on the books but rarely enforced. Only once the UBS thing broke did the IRS start cracking down. Then the OVDI happened, which presumes guilt (ie intentionally evading taxes) from the get go. So based on the timing, I always thought things got to the point they are because of swiss bank accounts and tax evaders. And I thought penalties were structured the way they were so the IRS could throw the book at those guys when they were caught.