CRA has finalized its revised VDP GST/HST Memorandum

CRA has made similar revisions in finalizing its Memorandum on the GST/HST (and excise) voluntary disclosure program as was the case for the ITA Circular, for example:

• The effective date is now March 1, 2018, meaning that applications received on and after that date will be categorized as falling into one of three categories: wash transactions (100% interest and penalty relief); general program (50% interest relief and 100% penalty relief); and limited program (no interest relief and penalty relief only for the gross negligence penalty).
• The limited program is now expressed to apply “where there is an element of intentional conduct on the part of the registrant or a closely related party.” (To show how closely integrated the drafting of the two VDP documents is, “closely related” is an ETA-defined term that was also used in the ITA Circular.)
• However, “generally, applications by corporations with gross revenue in excess of $250 million in at least two of their last five taxation years, and any related entities, will [only] be considered under the Limited Program.”

Neal Armstrong. Summary of 15 December 2017 GST/HST Memorandum 16.5 – Voluntary Disclosures Program under ETA s. 281.1(2).