Lawyers and Tax Lawyers

An experienced team of tax litigators, with an outstanding track record.

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  Volontary disclosure

The Voluntary Disclosures Program of both the Canada Revenue Agency (CRA) and Québec Revenue Agency (QRA or ARQ) are often modified. The CRA program will see substantial change in 2018. The ARQ has already announced that certain files will not qualify with regard to taxpayers investigated by the Charbonneau Commission for example and others in particular circumstances.

The Voluntary Disclosures Program gives you a second chance to change a tax return you previously filed or to file a return that you should have filed. You can apply to the Canada Revenue Agency (CRA) or the Québec Revenue Agency (QRA) to ask for relief of prosecution and penalties.

Anonymous intermediary with the tax authorities

Taxpayers who are uncertain about the program can, as a first step with an authorized representative, discuss their file anonymously. Anonymous voluntary disclosure is no longer possible since December 15th, 2017 with CRA and December 20th, 2019 with RQ.

If a full disclosure has been submitted, less the identity of the taxpayer, the tax authorities provide information concerning what the situation entails fiscally wise. These preliminary discussions do not bind the Government at this stage.

Our experts can provide support at each of the different stages : evaluation of your tax situation, anonymous intermediary with the tax authorities (anonymous disclosures are no longer possible), negotiation of instalment payments, assistance all along the disclosure process, revision and renegotiation of conditions.

Before providing information to tax authorities, it will always be a good idea to consult a professional who can assess potential problems and advise you on a secure path to proceed.

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Evaluation of your tax situation

Voluntary disclosure programs save Governments a lot of money when a taxpayer comes forward. Such programs are worthwhile. The Voluntary Disclosure's Program gives the taxpayer a chance to change a tax return previously filed or to file a return that should have filed. If the submission is accepted, the taxpayer can save penalties and avoid criminal prosecution. One very important criterion is that it is impossible to benefit from the program once an audit is underway. We can assess your tax situation help you decide the appropriate steps, and guide you all along.

Anonymous intermediary with the tax authorities

Both the Canada Revenue Agency and the Québec Revenue Agency no long accept anonymous voluntary disclosures. Anonymous disclosures have been replaced with the possibility of an anonymous discussion where the taxpayers can explain their situation to the authorities without providing their identity. Those prior discussions may not lead to an agreement about the voluntary disclosure's outcomes but the taxpayers can measure the risks they face.

Negotiation on instalment payments

Our experts and tax lawyers have experience with voluntary disclosures, and they are familiar with internal rules at CRA and QRA. Professional relationships established with different officers can facilitate the conclusion of settlements.

Follow-up of the voluntary disclosures process

The first step in the VD Program is to obtain a file number. Such a number is issued once the submission is judged receivable. After a file number is issued, the taxpayer is somehow protected against penalties should the taxpayer be audited afterward. This is conditional on full disclosure in the following months.

Revision and renegotiation of conditions

On rare occasions, it is possible to apply for an administrative review of unfavourable decisions rendered during the VD Program. We can evaluate your chance of success if such a situation occurs.