After a delay of almost 5 years CRA has announced its implementation of the Federal Court of Appeal decision in Bozzer v. Canada (2011 FCA 186). The effect of the policy change is that issues giving rise to taxpayer relief that are more than 10 years old will qualify for interest relief for a 10 year period going back from the date of the taxpayer relief application. CRA updated their information circulars IC00-1R5 Voluntary Disclosures Program and IC07-1 Taxpayer Relief Provisions to reflect the taxpayer victory in this tax case.
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