The CRA personnel dealing with voluntary disclosures (VDs) were quite busy in fiscal 2015. Michael Friedman and Andrew Stirling, “Voluntary Disclosures Continue To Increase” Canadian Tax Highlights 24:3 (March 2016) discusses some key points found in the CRA’s report to…
CRA Response
The CRA has responded to some Bad Press regarding the KPMG case, which I wrote about yesterday.
Secret deal for shelter participants
From the “what the hell were they thinking” file: the CBC reports that the CRA offered VD treatment (no prosecution, no penalties) to high net-worth participants in an offshore tax shelter marketed by KPMG. I wonder what change in policy…
New VD policy
The CRA has published an updated version of Information Circular IC00-1 (IC00-1R3 Voluntary Disclosure Program).
Coming soon to a taxpayer near you
In “Soliciting VDs?“, I wrote about the CRA’s “letter campaign”, which is supposed to “to inform taxpayers about their tax obligations and to encourage them to correct any inaccuracies in their past income tax and benefit returns.” The campaign continues,…
Voluntary disclosure legal fees
In a recent technical interpretation (2012-0434071E5), the CRA confirmed that legal fees incurred to prepare a voluntary disclosure application are not deductible under paragraph 60(o) of the Income Tax Act. Paragraph 60(o) permits the deduction of “amounts paid by the…
Involuntary VD
Livaditis v Canada Revenue Agency, 2012 FCA 55, is an interesting case on voluntary disclosures. The cases reminds us that the CRA gets to decide when a disclosure is voluntary, and the courts will not interfere with such a decision…
VD Case
A corporation withholds tax from a dividend that it pays to a non-resident and then fails to remit the amount withheld. The CRA later sends a letter to a shareholder of a shareholder of the dividend payor asking for information…