IRS Response To The PFIC Problem In The UBS Voluntary Disclosure Initiative Tanya M. Marcum is an assistant professor of law in the Department of Business Administration, Foster College of Business Administration, at Bradley University in Peoria, Illinois. She has taught law for over 12 years and has published 16 scholarly articles on various legal topics. She holds a BS. degree from Central Michigan University, 1983, and a J.D. from Thomas M. Cooley Law School, 1987. She is licensed to practice law in the State of Michigan. She served as General Counsel for the IRS in the Detroit and Grand Rapids offices for 10 years. She can be reached at tmarcumPbradleyedu. Sandra J. Perry is a professor of law in the Department of Business Administration, Foster College of Business Administration, at Bradley University in Peoria, Illinois. She has taught law for over 29 years and has published 29 scholarly articles on various legal topics. She holds a B.S. degree from Bradley University, 1976, and a J.D. from Southern Illinois University School of Law, 1979. She is licensed to practice law in the State of Illinois. She can be reached at sioftbradlev. edu. Tanya M. Marcum and Sandra J. Perry With a high volume of cases, a lack of informa- tion, and harsh penalties, voluntary disclosure of PFIC income presents the perfect storm for taxpayers. THE RECENT SURGE in enforcement of US. tax law by the IRS for non-reporting of foreign income coupled with the complicated tax treatment of passive foreign in- vestment companies (PFICs) threatened to create a per- fect storm for the taxpayers, their representatives, and the IRS. Thousands of U.S. taxpayers have come forward to participate in the IRS's voluntary disclosure initiative fol- lowing the UBS agreement in order to disclose to the US. their identities and account information. Much of this previously unreported income is subject to harsh tax treat- ment requiring detailed financial i