CRA indicated that taxpayers potentially can make a 2nd VDP disclosure

CRA indicated in May 2016 that it will accept a second disclosure by a taxpayer under the voluntary disclosure program respecting an unrelated issue (assuming that the usual four conditions set out in its Circular are satisfied). A second disclosure also will be accepted respecting a related issue where the taxpayer’s non-compliance was due to factors beyond its control, e.g., an employee receiving an amended T4, or an executor receiving an unexpected bank statement re a foreign asset (changing amounts in a T1135 VDP filing).

Neal Armstrong. Summary of May 2016 Alberta CPA Roundtable, Q.11 under s. 220(3.1).