Lawyers and Tax Lawyers

An experienced team of tax litigators, with an outstanding track record.

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  Volontary disclosure

The Voluntary Disclosures Program of both the Canada Revenue Agency (CRA) and Québec Revenue Agency (QRA or ARQ) are often modified. The CRA program will see substantial change in 2018. The ARQ has already announced that certain files will not qualify with regard to taxpayers investigated by the Charbonneau Commission for example and others in particular circumstances.

The Voluntary Disclosures Program gives you a second chance to change a tax return you previously filed or to file a return that you should have filed. You can apply to the Canada Revenue Agency (CRA) or the Québec Revenue Agency (QRA) to ask for relief of prosecution and penalties.

Anonymous voluntary disclosure

Taxpayers who are uncertain about the program can, as a first step with an authorized representative, submit their file anonymously. The authorized representative must complete Form 199 to start the process ( RC199 Voluntary Disclosures Program (VDP) Taxpayer Agreement).

If a full disclosure has been submitted, less the identity of the taxpayer, the tax authorities provide information concerning what the situation entails fiscally wise. These preliminary discussions do not bind the Government at this stage.

Our experts can provide support at each of the different stages : evaluation of your tax situation, authorized representative for anonymous disclosure, negotiation of instalment payments, assistance all along the disclosure process, revision and renegotiation of conditions.

Before providing information to tax authorities, it will always be a good idea to consult a professional who can assess potential problems and advise you on a secure path to proceed.

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Evaluation of your tax situation

Voluntary disclosure programs save Governments a lot of money when a taxpayer comes forward. Such programs are worthwhile. The Voluntary Disclosure's Program gives the taxpayer a chance to change a tax return previously filed or to file a return that should have filed. If the submission is accepted, the taxpayer can save penalties and avoid criminal prosecution. One very important criterion is that it is impossible to benefit from the program once an audit is underway. We can assess your tax situation help you decide the appropriate steps, and guide you all along.

Anonymous authorized representative

Both the Canada Revenue Agency and the Québec Revenue Agency accept anonymous voluntary disclosures. The identity of the taxpayer will be revealed once an agreement is reached. Should there be no agreement, the taxpayer can get out of the process. That situation is rare since 99 % of all disclosures will end in some agreement.

Negotiation on instalment payments

Our experts and tax lawyers have experience with voluntary disclosures, and they are familiar with internal rules at CRA and QRA. Professional relationships established with different officers can facilitate the conclusion of settlements.

Follow-up of the voluntary disclosures process

The first step in the VD Program is to obtain a file number. Such a number is issued once the submission is judged receivable. After a file number is issued, the taxpayer is somehow protected against penalties should the taxpayer be audited afterward. This is conditional on full disclosure in the following months.

Revision and renegotiation of conditions

On rare occasions, it is possible to apply for an administrative review of unfavourable decisions rendered during the VD Program. We can evaluate your chance of success if such a situation occurs.