Moreover, because the 2009 OVDP closed on October 15, 2009, if Governor Romney had participated in that program, his 2009 return (and likely also his 2008 return) would not evidence his participation in the OVDP, and thus could be released without raising any questions regarding his compliance with his offshore account disclosure obligations.
FORBES: What Does The Flap Over Romney's Tax Returns Suggest About Disclosure of His Swiss Account?