A takeway point from the WSJ article is that some practitioners believe that a UBS disclosure of names of persons not yet in the Voluntary Disclosure program will close off their opportunity to join the program. I quote the article:
If UBS discloses names and information as part of a settlement, the IRS will “generally not accept a voluntary disclosure from anyone on that list,” says Mr. Michel. Further, he adds, a settlement in this case “could come any day and be accompanied by disclosure.” So, unless the IRS gives everyone until Sept. 23, the expiration date for a settlement initiative now in place, the window for voluntary disclosures may be closing fast for many.The Mr. Michel quoted is a prominent attorney in this area of the law (see bio here).
So, the message is the steady drumbeat -- Get in Line Brother, but do so Quickly.