Are VD fees (voluntary disclosure fees) deductible? The CRA takes the position that, in general, professional fees incurred in respect of a VD are not deductible unless they were incurred in respect of a business. Per 2016-0625731C6, when the CRA has accepted a voluntary disclosure but revised the income or the tax payable under the VDP, the CRA “generally will allow the deduction, under paragraph 60(o), for professional fees incurred from that time onwards by the taxpayer in advancing its claims respecting the revision.” This confirms 2012-0434071E5, which I discussed here.
