CRA intends for taxpayer to rely on appropriate exercise of discretion by senior auditors in voluntary disclosure matters when the new VDP takes effect later in 2018
Q.1 CRA explained that a major driver in its decision to make the voluntary disclosure program more stringent (along with pressure from the Finance Committee in the House of Commons) was CRA’s increasing confidence in its ability to detect high-risk taxpayers for audit.
Q.2, Q.15 The increase in CRA discretion under the revised program should be acceptable because there will be a group of three or four senior auditors whom representatives will be able to speak to on a no-names basis and who will have the judgment to give reliable guidance.
Q.8 There likely will be a delay in the implementation date for the new program until at least the summer of 2018 or perhaps October, although this decision is up to the Minister. Further major changes (or eliminating the VDP entirely) likely will not occur, if at all, for another three years.
Q.16 The revised Circular will be generally similar to the draft Circular.