CRA will not provide voluntary disclosure relief from interest if the taxpayer has been insufficiently naughty

In IC 00-1R3, CRA stipulates that "a [voluntary] disclosure must involve the application, or potential application of a penalty."  Esmail Bharwani asserts that "many accountants complain that CRA has decided in many of the cases that they would not have applied a gross negligence penalty, therefore the non-filer taxpayer would not qualify.  So what was supposed to have been a VD request with possible waived penalties and cancelled partial interest arrears has now become subject to regular filing, with penalties and interest."

Neal Armstrong.  Summary of Esmail Bharwani, "Voluntary Disclosures", CGA Magazine, March – April, 2014, p. 48 under s. 220(3.1).