Don't Delay, Disclose Today: Substantial Changes To The Voluntary Disclosures Program To Be Effective March 1, 2018

On December 15, 2017, the Canada Revenue Agency ("CRA") released two highly-anticipated policy statements outlining several changes to its Voluntary Disclosures Program (the "VDP"). By and large, the changes narrow the application of the program, limit — and in some cases, eliminate — relief available in various circumstances, and introduce more onerous criteria for access to the program.

Key changes to the VDP include:

• The introduction of a two-track program for income tax disclosures and a three-track program for GST/HST disclosures;
• A general requirement that estimated taxes be paid when a disclosure is made;
• An expansion of the circumstances in which a voluntary disclosure will not be considered or will be considered only with limited benefits; and