In April 2016, the Minister of National Revenue established the
Offshore Compliance Advisory Committee (“OCAC”) for the
purpose of advising the Minister and the Canada Revenue Agency
(“CRA”) on administrative strategies to deal with
offshore compliance. In the fall of 2016, OCAC issued a report on
CRA’s Voluntary Disclosure Program, which was endorsed by the
Minister of National Revenue on December 8, 2016. On February 22,
2017, the CRA released its formal response, in which it indicated
that the review of the recommendations prepared by OCAC will be
completed by March 31, 2017.
In its report, OCAC makes numerous recommendations that, if
implemented, will radically alter the Voluntary Disclosure Program,
generally reducing the value of such disclosures and increasing
taxpayers’ compliance costs. OCAC recommends reducing the
value of relief available to a taxpayer in certain circumstances,
in which a high degree of taxpayer culpability contributed to the
failure to
