Income tax – Overview

Who can apply?

Taxpayers (including individuals, employers, corporations, partnerships, or trusts) can make an application to the Voluntary Disclosures Program (VDP).

Income tax stream applications

The Voluntary Disclosures Program (VDP) gives you a chance to change a tax return you previously filed or to file a return that you should have filed. You can submit a VDP application to request relief from prosecution, penalties, and some of the interest you would otherwise be required to pay for disclosures relating to the income tax act.

Examples of what an income tax stream application may involve are:

  • omitted or underreported income
  • expenses claimed in error
  • failure to remit source deductions for employees (i.e. Canada Pension Plan / Quebec Pension Plan deductions)
  • failure to file an information return (i.e. T1135 Foreign Income Verification Statement)

For more information, go to IC00-1R6, Voluntary Disclosures Program.

Tracks under the income tax stream

Effective March 1, 2018, income tax stream applications are processed under one of two tracks: the General Program and the Limited Program. The determination of which track an application will be processed under will be made by the VDP on a case-by-case basis.

Track 1 - General Program

The General Program provides relief to taxpayers who want to correct unintentional errors. If your application is accepted into the General Program, you will not be charged penalties and will not be referred for criminal prosecution related to the information disclosed.

Through the General Program, you may be granted partial relief of interest for assessments for the years preceding the three most recent years of returns that must be filed. Generally, this interest relief will be a reduction of 50% of the applicable interest rate that applies for those years. Full interest charges will be assessed for the three most recent years of returns required to be filed.

Track 2 - Limited Program

The Limited Program limits the level of relief for taxpayers who intentionally avoided their tax obligations. If your application is accepted into the Limited Program, you will not be referred for criminal prosecution related to the information disclosed and you will not be charged gross negligence penalties. However, you will be charged other penalties as applicable.

No interest relief will be provided for applications processed under the Limited Program.

The following factors may be considered in determining if an application is accepted into the Limited Program:

  • efforts were made to avoid detection through the use of offshore vehicles or other means
  • the dollar amounts involved
  • the number of years of non-compliance
  • the sophistication of the taxpayer
  • if the disclosure is made after an official CRA statement regarding its intended specific focus of compliance (for example, the launch of a compliance project or campaign) or following broad-based CRA correspondence (for example, a letter issued to taxpayers involved in a particular sector about a compliance issue) 

The existence of a single factor will not necessarily mean that you are eligible only for the Limited Program. For example, a sophisticated taxpayer may still correct a reasonable error through the General Program.

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