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ARTICLE · 10 JULY 2017

Providing VDP Relief - Voluntary Disclosures Program Proposed Changes - Toronto Tax Lawyer Analysis

The proposed changes to the voluntary disclosures program significantly narrow the scope of relief available to taxpayers.

CanadaTax

Introduction – Voluntary Disclosures Program Proposed Changes

The Voluntary Disclosures Program (VDP or tax amnesty) is a Canada Revenue Agency (CRA) program that allows Canadian taxpayers to come forward and correct their tax mistakes provided that certain requirements are met. Currently, in order for a taxpayer's voluntary disclosure to be accepted, four requirements must be met. First, there cannot be any ongoing enforcement action in place against the taxpayer with respect to the issues being disclosed. Second, the disclosure must be complete. Third, the disclosure must involve the application of a penalty or the potential application of a penalty. Fourth, the disclosure must include information that is at least one year past due. If these requirements are met and the taxpayer's voluntary disclosure is accepted, then the CRA will provide full penalty relief, partial interest relief and refrain from pursuing criminal charges against the taxpayer.

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