According to an OVDP hotline representative (whose advice is not binding), the IRS highly recommends that both spouses enter the program where joint returns were filed during the disclosure period.

FORBES: Must You Enter IRS Offshore Disclosure With Your Spouse?

It has proposed an amendment to the pact that would replace the legally binding language with a provision that retailers that failed to live up to the standards be publicly expelled from the program.

WSJ: Wal-Mart Announces Own Bangladesh Safety Plan