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Your Voluntary Disclosure Application Was Denied: What Happens Next?

What happens after CRA denies a Voluntary Disclosures Program application, including the second review process and judicial review options.

Tax5 min readTSLBy the Treadstone Law team · OntarioUpdated 2026-07
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Key takeaways
  • If CRA reassesses your tax return and you disagree with the amount, your path runs through a Notice of Objection and, if needed, an appeal to the Tax Court of Canada.
  • Most denied applications can first be brought back to CRA for an independent second review, typically conducted by a different, more senior official than the one who made the original…
  • If the second review also results in a denial, the next step is judicial review, but it goes to the Federal Court, not the Tax Court of Canada.

A denied Voluntary Disclosures Program (VDP) application feels final, but it usually is not the end of the road. Because a VDP decision is a discretionary administrative decision, not a tax assessment, the way you challenge it is different from disputing a reassessment. Here is how the recourse actually works.

Why a Denial Is Different From a Reassessment

If CRA reassesses your tax return and you disagree with the amount, your path runs through a Notice of Objection and, if needed, an appeal to the Tax Court of Canada. A denied VDP application is not that kind of dispute. The Tax Court of Canada hears appeals about the correctness of a tax assessment — it does not review CRA's discretionary decision about whether to grant voluntary disclosure relief. Taking a denied VDP application to the Tax Court is generally the wrong forum entirely.

Step One: An Internal Second Review

Most denied applications can first be brought back to CRA for an independent second review, typically conducted by a different, more senior official than the one who made the original decision. This step stays entirely within CRA — you are asking the agency to look again at the same facts, or at new information you can add, before escalating anywhere else.

A second review is worth taking seriously: it is your best opportunity to correct a misunderstanding, supply missing documentation, or clarify a fact CRA may have weighed incorrectly the first time, without involving a court.

Step Two: Judicial Review at the Federal Court

If the second review also results in a denial, the next step is judicial review, but it goes to the Federal Court, not the Tax Court of Canada. This distinction trips people up because both have "Court" in the name and both deal with CRA, but they do fundamentally different jobs:

Tax Court of CanadaFederal Court
ReviewsWhether a tax assessment is correctWhether CRA's discretionary decision was reasonable
Applies toReassessments, GST/HST assessmentsVDP denials, taxpayer relief denials
Can it recalculate my tax bill?YesNo
Typical remedyVacates, varies, or confirms the assessmentSends the decision back to CRA for redetermination

The Federal Court does not decide whether you should get VDP relief — it decides whether CRA's decision-making process was reasonable, whether it considered the relevant facts, and whether it followed a fair process. If the Federal Court agrees the decision was unreasonable, the typical result is not that the court grants relief itself, but that the matter goes back to CRA for a fresh decision.

What to Expect Along the Way

Frequently asked questions

Is there a deadline to ask for a second review or judicial review?

Yes, deadlines apply at each stage, and missing one can close off that avenue entirely. Confirm the specific deadline that applies to your denial as soon as you receive it, rather than assuming you have unlimited time.

Can I skip the second review and go straight to Federal Court?

Generally, judicial review is meant to follow CRA's own internal review process rather than bypass it, though the specifics depend on your situation. It is worth confirming this sequencing before you file anything.

If the Federal Court sends my case back to CRA, does that mean I'll get relief?

Not necessarily. A successful judicial review typically means CRA has to make the decision again, properly this time — it does not guarantee the new decision will be in your favour, only that it will be reconsidered on a sound basis.

Does a denied VDP application mean I still owe everything, including the reduced penalties I hoped for?

Yes. If your application is denied, your situation is generally treated as if the VDP relief was never granted, and any return or correction you filed is processed under the normal rules, including full penalties and interest, unless a later review changes that outcome.

This article is general information, not legal advice. Reading it does not create a lawyer-client relationship. Ontario laws, tax rates, and government programs change, and how the law applies depends on your specific facts. For advice about your situation, speak with a licensed Ontario lawyer. Treadstone Law is licensed by the Law Society of Ontario — reach us at 1-844-900-1070 or start a file online.

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