In the fall of 2016, the Offshore Compliance Advisory Committee
issued a report on the CRA's voluntary disclosures program (the
"Report"), which Report was endorsed by the Minister of
National Revenue in December. On February 22, 2017, the CRA
announced that its review of the recommendations regarding the
Report will be completed by March 31, 2017.
The Report proposed numerous changes to the voluntary
disclosures program, the effect of which will likely reduce the
benefits available under the program. The Report recommends that
the amount of relief available to a taxpayer should be reduced
where external factors indicate a high level of culpability on the
part of the taxpayer. Factors such as the length of non-compliance,
the dollar amounts of tax owing, the deliberateness of
non-compliance and the sophistication of the taxpayer would be
taken into account when determining the quantum of relief granted.
Assuming this recommendation is taken up, there is a
