Dubbed the “Panama Papers,” an extensive 11 million document trove from Panamanian law firm Mossack Fonseca was leaked to Süddeutsche Zeitung, Germany’s largest national subscription newspaper; it has been analyzed by the International Consortium of Investigative Journalists and other publications.

The leak is said to provide an inside look into an expansive network used by the world’s elite to hide assets.  The leak provides a paper trail of nearly 40 years of records on bank accounts opened and business structures created in Panama by these individuals, which many journalists are asserting were created for illegal purposes, specifically, to take advantage of Panama’s infamous bank secrecy laws in an effort to avoid taxes.

This leak implicates hundreds of individuals including world leaders, and their families and associates, such as Vladimir Putin, Xi Jinping, the King of Saudi Arabia and Iceland Prime Minister Sigmundur Davíð Gunnlaugsson, who, in response to the leak, has resigned his position.

Undoubtedly, the IRS will be parsing through the documents themselves attempting to uncover taxpayers who are subject to U.S. taxation who may have been delinquent, deliberately or otherwise, in reporting foreign assets.  Those individuals, and others with undisclosed foreign assets, may still come clean and avoid potential civil and criminal penalties by entering into the disclosure programs offered by the IRS.

The Offshore Voluntary Disclosure Program, Streamlined Filing Compliance Procedures and Reasonable Cause are avenues for those with undisclosed foreign assets who wish to come into compliance with their U.S. tax filing obligations.  Each of these options come with its advantages and disadvantages.  For example the Offshore Voluntary Disclosure Program provides a structured settlement program with a known outcome, the Form 906 closing agreement, however the penalties associated with this program are significant.