CRA has confirmed its position that the costs incurred to make a voluntary disclosure are not deductible under paragraph 60(o) (which allows for the deduction of costs related to filing an Objection or Appeal) nor would they generally be incurred to earn income from a business or property. In cases of a taxpayer who earns income from a business, the cost of filing a voluntary disclosure relating to that business may be deductible as a cost of representation pursuant to paragraph 20(1)(cc).
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