The Canada Revenue Agency's Voluntary Disclosure
Program (VDP) has gone through a number of organizational changes
over the past few years. For many years, disclosures were made to
the local Tax Services Office. More recently, the CRA has moved the
handling of disclosures to Regional Centres; Shawinigan – Sud
Tax Centre for the Atlantic, Quebec, and Ontario Regions, Winnipeg
Tax Centre for the Prairie Region and Surrey Tax Centre for the
With the move of the VDP to Regional Centres, the CRA has
implemented a new screening process. Screeners are now reviewing
disclosure packages soon after receipt and are comparing the
package to a CRA developed checklist. If any item on the checklist is
missing or incomplete, then the CRA returns the package to the
sender, along with a covering letter and a checklist that
identifies the missing or incomplete information. There are,
however, certain issues that have arisen with respect
to the CRA's screening process and use of the
First, it prevents a disclosure from being made by a taxpayer
who does not have a social insurance number, business number, etc.
If an identification number is not available, the disclosure may
need to be made on a no-names basis while the taxpayer applies for
an identification number.
Second, the CRA will not accept a disclosure if the amount in
issue is not identified. This is problematic as, often, disclosures
are made before the work needed to calculate the omitted or
under-reported amount has been completed. In the past, this
information was forwarded within 90 days of filing the disclosure
and was an approach acceptable to the CRA.
Third, where the disclosure package is large, screeners do not
appear to be reviewing all of the documents before issuing the
letter and checklist. Therefore, it is advisable to use a covering
letter for each disclosure package which identifies compliance with
each item on the CRA's checklist and a detailed explanation as
to why any checklist item is outstanding. It is not yet clear
whether, even upon explanation, the CRA will accept a disclosure if
a checklist item is outstanding.
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