For taxpayers who have not been meeting their reporting requirements, CRA had provided the Voluntary Disclosures Program. The Voluntary Disclosures Program allows Canadian taxpayers that proactively come forward with their unreported or unfiled foreign income and assets to avoid prosecution for tax evasion and receive partial interest relief along with the waiver of all monetary penalties. One of the key requirements of the Voluntary Disclosures Program is that it must be voluntary; if CRA contacts a non-compliant individual first, they can no longer utilize the Voluntary Disclosures Program. To be protected by the Voluntary Disclosures Program, a taxpayer must make a declaration that they are coming forth with a disclosure before CRA contact occurs. CRA "contact" encompasses any enforcement action set to be conducted by CRA, or enforcement action conducted by CRA on a person associated with or related to the taxpayer where the undisclosed information was likely to have been uncovered. Out top Canadian tax lawyers deal with voluntary disclosures every day.
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