CRA - Voluntary Disclosure Program policy change for no-name disclosures

The Canada Revenue Agency's (CRA) Voluntary Disclosures Program (VDP) is a fairness initiative that gives taxpayers the opportunity to come forward and to correct inaccurate or incomplete information, or to disclose previously-unreported information, without penalty or prosecution that would otherwise be imposed.

Information Circular IC00-1R2, Voluntary Disclosures Program , provides you with further information in respect to the VDP. Paragraph 11 of that information circular refers to our policy concerning voluntary disclosures submitted on a no-name (hypothetical) basis. This no-name disclosure policy provides taxpayers and their representatives an opportunity to gain insight into the implications of making a disclosure before any identification information is exchanged with CRA. We have updated this no-name disclosure policy and we would like to provide you with this update at this time. Also, as we are presently reviewing this information circular we will be making these changes and others as will be considered necessary.

No-Name Voluntary Disclosure Policy

The no-name disclosure policy provides that should a taxpayer decide to proceed with a no-name (hypothetical) disclosure the identity of the taxpayer must be provided to the CRA within 90 calendar days from the "effective date of disclosure". The "effective date of disclosure" for a no-name disclosure is either the date of receipt by a CRA tax services office of a written voluntary disclosure submission or the receipt of a completed form VDP-1 - Taxpayer Agreement Form, as used for the VDP.

During this 90-day period the taxpayer is protected from the application of penalty and from prosecution. The no-name voluntary disclosure file will be closed, without further contact from the CRA, if at the end of this 90-day period the identity of the taxpayer remains unknown. No extension to this 90-day period will be allowed to identify the taxpayer.

In addition, a final and complete submission of the disclosure is expected within these 90-days.