Can a Corporation Make a Voluntary Disclosure for Unfiled T2 Returns in Canada?

This answer covers Canadian federal tax law, which applies in every province.

Yes, corporations can apply to the Voluntary Disclosures Program (VDP). The CRA lists not filing a return that is now a year late, and not reporting or under-reporting income, among the income tax situations that may be eligible. If the application is accepted, the CRA may give penalty and interest relief, but the tax must still be paid in full.

The application must be voluntary and complete, must involve interest, penalties or both, must include information at least one year past the filing due date, and must include payment of the estimated tax owing or a request for a payment arrangement. The application includes the signed Form RC199, all returns, forms and schedules needed to correct the non-compliance, and payment or a payment arrangement request. For a corporation, that would include the missing returns themselves and any corrected ones.

If a representative files for you, both the taxpayer and the representative must sign. Insolvency for the years involved is generally not eligible. Relief depends on whether the CRA has already contacted the corporation about the issue. A lawyer or accountant can confirm how this applies to your corporation.