Can I Use the VDP After the CRA Has Already Contacted Me in Canada?

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

Possibly, yes. A CRA letter or notice about a specific issue does not by itself end eligibility. The CRA treats such an application as prompted, with partial relief, if you are not under audit or investigation.

The line that matters is audit or investigation. A disclosure is not voluntary if an audit or investigation has been initiated against you or a related taxpayer for the disclosed information, including by law enforcement, securities commissions or other regulators, not just the CRA. An application is generally prompted if it follows CRA communication identifying a specific error or setting a correction deadline. A general education letter alone does not make it prompted. Prompted applications normally receive 25% relief of the applicable interest and up to 100% relief of the applicable penalties.

Other conditions still apply, such as a complete application with payment or a payment arrangement request. If you are unsure, you may hold informal, non-binding preliminary discussions with the CRA on an anonymous basis. Because the category depends on what the CRA has sent you, have the letter reviewed by a lawyer or accountant before you file.