Ryan Rabinovitch, Angelo Discepola, "Solving Sales Tax Non-compliance Through the Canadian Voluntary Disclosure Program"

Voluntary disclosure for series of GST returns only one of which is more than one-year overdue (p. 1176)

[T]he disclosure must generally include...

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CRA’s voluntary disclosure practice is to go back only to years for which there is supporting documentation, and no earlier

Although CRA can go back more than four years where there has been a neglectful misrepresentation etc., “in practice, however, the CRA will (by...

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