If you fail to file a duly completed mandatory disclosure form by the deadline, we can exercise our power of assessment at any time with regard to the tax consequences resulting from undisclosed tax planning schemes.

In addition, you may incur a penalty of at least $10,000, to which $1,000 per day will be added as of the second day the form is late, up to a maximum of $100,000.

Lastly, if the general anti-avoidance rule (GAAR) applies to the undisclosed tax planning scheme, the penalties provided for by law will also apply.