You really have to wonder about the mental stability of an executive who would take the rules of a program, that he himself admits was working, and make them worse rather than better.  How does Mr. Shulman think that more people will be encouraged to enter the program when he has just increased by a full third, the years of required tax filing and has lumped the non willful violators in with the willful ones?  Of course by going back two more years he hits a spot in the economic cycle when the world economy was doing well.  This would then increase any revenues that could be gained from capital gains and since account sizes would increase so then would the base upon which to assess penalties on those accounts.

Of course the unknown duration of this new amnesty and the fact that we are “warned” that the penalties could change at any time is the terror component that weighs on us all.  I guess that there is no intimidation like that which can be exercised by the “STATE” over its citizens.

I think that they answer may be that he never intended to have the previous program succeed.  Maybe what he is really waiting for is FATCA to kick in, so that the IRS worldwide enforcement net will either force more people to come forward or else punitively punish the recalcitrant account holders.  Either way you look at it the little guy of modest means will lose.  Wealthy Americans will be able to buy their way out of this mess and the rest of us will suffer inordinately the slings and arrows of U.S. arrogance.