to assist such employees in obtaining and evaluating information and determining whether there exists a restricted period with respect to a company with a single-employer defined benefit plan, and whether such a company has, during a restricted period, set aside assets for the purpose of paying deferred compensation under a nonqualified deferred compensation plan. (D) Income inclusion for offshore trusts and employer's financial health For each taxable year that assets treated as transferred under this paragraph remain set aside in a trust or other arrangement subject to subparagraph (A), (B), or (C), any increase in value in, or earnings with respect to, such assets shall be treated as an additional transfer of property under this paragraph (to the extent not previously included in income). (E) Interest on tax liability payable with respect to transferred property (i) In general If amounts are required to be included in gross income by reason of subparagraph (A), (B), or (C) for a taxable year, the tax imposed by this chapter for such taxable year shall be increased by the sum of— (I) the amount of interest determined under clause (ii), and (II) an amount equal to 20 percent of the amounts required to be included in gross income. (ii) Interest For purposes of clause (i), the interest determined under this clause for any taxable year is the amount of interest at the underpayment rate plus 1 percentage point on the underpayments that would have occurred had the amounts so required to be included in gross income by subparagraph (A), (B), or (C) been includible in gross income for the taxable year in which first deferred or, if later, the first taxable year in which such amounts are not subject to a substantial risk of forfeiture. (7) Exception for highly compensated recipients In the case of any highly compensated employee (as defined in section 414(q)), or any person who would be such a highly compensated employee if such person were an employee of the service recipient (determined as of the date of the grant of