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ARTICLE · 29 SEPTEMBER 2021

Voluntary Disclosures Program Update – The New Normal

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The Canada Revenue Agency ("CRA") voluntary disclosures program ("VDP") has been around for decades. While the VDP has changed periodically, perhaps the most significant change occurred when the...

CanadaTax
Stevan Novoselac
Stevan Novoselac
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The Canada Revenue Agency ("CRA") voluntary disclosures program ("VDP") has been around for decades. While the VDP has changed periodically, perhaps the most significant change occurred when the new Information Circular IC00-1R6, initially published on December 15, 2017, became effective on March 1, 2018. After making some general comments about the VDP, this article highlights some of the major differences, before and after March 1, 2018, in the CRA's policy and practice.

VDP background

The purpose of the VDP has always been to allow taxpayers to come forward to correct their mistakes and/or omissions and pay their tax. To incentivize taxpayers, the CRA reduced the interest, waived civil penalties and agreed to not pursue potential criminal prosecution for tax evasion. The two main conditions for acceptance under the VDP were that the application had to be voluntary and complete; voluntary in the sense that the application was filed before the CRA had commenced

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