Voluntary Disclosure
In the case of a first-time voluntary disclosure, the underpaid tax, plus late-payment interest, is assessed for the past five years. For the purposes of determining whether it is a first-time disclosure, voluntary disclosures filed after January 1, 2011, are taken into account. For each subsequent voluntary disclosure, in addition to the unpaid tax plus interest, a penalty equal to 20% of the unpaid tax is due.