Overview: A CRA refusal can turn a compliance strategy into a CRA dispute
A voluntary disclosure can be one of the most effective ways for a Canadian taxpayer to correct past non-compliance before the CRA becomes fully involved. A successful application under the CRA Voluntary Disclosures Program can provide relief from penalties, partial or full interest relief, and protection from criminal prosecution for the disclosed issues. But a voluntary disclosure is not automatically accepted. Since the CRA reviews each application on its own facts and may refuse relief if the application does not meet the program requirements, preparation by a knowledgeable Canadian tax lawyer is essential.
For taxpayers, the rejection of a voluntary disclosure is serious. It does not simply mean that the taxpayer is back where they started. The CRA may now have detailed information about unreported income, unfiled returns, GST/HST reporting errors, payroll remittance failures, or other compliance issues.
