I am informed by the Revenue Commissioners that where a person has used an offshore account for the purposes of concealing income or gains which were not disclosed for tax purposes, they take steps to pursue the outstanding tax liabilities together with interest and penalties. Where the person in question is deceased, the law provides that the tax liability together with interest and penalties are payable out of his or her estate. Accordingly, Revenue seeks to recover the appropriate sums from the executor or administrator of the relevant estate. Under the recent voluntary disclosure scheme for offshore accounts, penalties for all periods after 5 April 1991 were mitigated to 10% of the tax outstanding. However, the Revenue Commissioners are precluded from mitigating penalties for earlier periods as those periods are governed by the 1993 amnesty provisions. The Revenue Commissioners have asked that where a taxpayer has difficulty in meeting a liability, he or she should contact the local revenue district.