The Voluntary Disclosures Program lets you correct past returns and avoid penalties and criminal prosecution. Since 1 October 2025 the rules are simpler and the relief is better — but only if you get there first. Once the CRA opens an audit on the issue, the door closes.
Our charges include applicable taxes. Disbursements are extra and billed at cost — itemized upfront, in writing, never hidden.
From $563.87 taxes included
Two things: money, and protection from prosecution. Every accepted disclosure gets full relief from penalties, including gross negligence penalties. Interest relief depends on how you got there — 75% of the interest if the CRA had not contacted you about the issue, 25% if it had. The CRA also does not refer an accepted disclosure for criminal prosecution.
What you do not get is relief from the tax. The unreported income is still taxable and you still owe it, along with the interest that is not waived. The VDP is about killing the penalty layer, which on unreported foreign assets or years of unfiled returns is often the larger number.
Relief is discretionary. The CRA can accept a disclosure and still grant less than the stated relief where the file warrants it, and it can reject an application outright.
An application is unprompted if you file before the CRA has communicated with you about the specific compliance issue. General mail does not count against you — an education letter or a broad reminder about reporting obligations will not make your application prompted.
It becomes prompted once the CRA has raised the issue with you, or once a third party has reported you. A tip from a former spouse or employee, or account information received from a foreign tax authority under an exchange agreement, is enough to move you into the lower tier.
There is a third category and it is worse than both. If an audit or investigation has already been started against you or a related person on that issue, the disclosure is not voluntary at all and the program is closed. This is why timing beats polish: a disclosure filed this month on reasonable estimates usually beats a perfect one filed after the audit letter lands.
Complete means complete. Every year affected, every entity you control, every account. Disclosing three of six offshore accounts is not a partial win — it is a rejected application, and the CRA now has the three you named.
You file with the returns or amended returns, supporting records, and payment of the estimated tax owing or a request for a payment arrangement. Where foreign income is involved, late foreign income verification statements almost always form part of the package.
You can have an anonymous pre-disclosure discussion with a CRA officer first to test eligibility and likely relief. It is informal and non-binding — nothing said in it commits the agency — but it is useful when the facts are ugly and you want a read before naming yourself.
Solicitor-client privilege. What you tell us about unreported income cannot be compelled from us by the CRA. Your accountant has no equivalent protection: their working papers and their recollection of your conversation are both obtainable, and in a file that could turn criminal, that difference matters.
We work with your accountant, not around them. They rebuild the numbers; we handle the disclosure, the correspondence with the CRA and the privilege boundary. Where the exposure is large or the conduct is hard to explain, that split earns its cost on its own.
Not on an accepted disclosure. The CRA does not refer accepted VDP applications for criminal prosecution and does not apply gross negligence penalties to them. That protection is the main reason the program exists. It disappears the moment an investigation starts on its own, which is why the value of coming forward drops sharply once the CRA is already looking at you.
As far back as the non-compliance goes — there is no point where old years stop mattering for the completeness test. Relief from penalties and interest, however, is limited to the ten calendar years before the year you apply, so a 2026 application generally reaches back to the 2016 tax year. Older years can still be assessed for the tax itself where there was misrepresentation.
Yes, and it is the most common use of the program. Unfiled foreign income verification statements carry their own penalty that accrues for each year missed, entirely separate from tax on the income. Canada exchanges financial account information automatically with most countries, so assuming the CRA will never find out is no longer a realistic position.
Treat it as a one-time door. A second application covering the same or a similar issue is unlikely to be accepted, and a repeat applicant is not viewed as someone who corrected their behaviour. Get the first one complete and right.
Open your file tonight — a licensed Ontario lawyer will confirm everything with you by tomorrow.