It’s mid-September and people are still seeking Alan Kirzner’s advice about disclosing previously secret offshore accounts.

“I just got a call recently where an existing client said, ‘Listen, do you know a good tax attorney? I have an issue,’” said Kirzner, a partner with Goldstein Schechter Koch. “I asked them what it was about, and he said, ‘Well, I have accounts offshore.’”

The IRS has set a September 23 deadline for disclosing such accounts under a so-called amnesty program. Afterward, penalties could be much more severe, including prison time or seizure of funds.

It’s not surprising that Kirzner’s phone would be ringing because his office is in Coral Gables, Florida, one of the nation’s most affluent and internationally oriented cities.

Still, Kirzner said he’s somewhat surprised people have waited this long to do something about the upcoming deadline—but he realizes disclosure can be difficult.

“I tell them I’m going to recommend an attorney, and they usually retain us to oversee filing the forms,” Kirzner said.

Kirzner said the most innocent failures to disclose offshore accounts come from two scenarios:

• Company executives with ultimate signing power over accounts in foreign banks may not realize they are supposed to disclose that authority.

• U.S. residents with parents in other countries may not realize they are required to disclose accounts to the IRS if they have power of attorney over their parents’ accounts in other countries.

The process is to file a disclosure along with an explanation of why the account has not been previously disclosed. If the IRS agrees the taxpayer meets the amnesty conditions, a payment of 5 percent to 25 percent of the highest balance over the past six years can be assessed.

With the crash of global stock markets, that could be the entire amount of a fund’s current balance.

An attorney is needed in case the IRS says the disclosure did not meet the amnesty conditions, Kirzner said.

The IRS recently reached a settlement with Swiss bank UBS over efforts to force disclosure of its accounts where the U.S. alleged the bank had aided tax evasion for U.S. citizens. In that case, the government had estimated there were 52,000 accounts. Under the terms of the settlement, the bank will disclose only accounts held by trusts or third parties, so individual names may not be disclosed. Two South Florida yacht brokers have already been hit with tax-evasion charges in connection with bank accounts at UBS.

In the last month, the IRS released a short form to enter the amnesty program by the deadline.

“We want to streamline the process and make it easier for taxpayers to come forward before the September 23 deadline,” IRS spokesman Mike Dobzinski said. “The form gives taxpayers a better understanding of what is needed to better determine their eligibility.”

In the last week of July, the agency received 400 applications, he said.

The pace was expected to pick up as the deadline neared.