The Canada Revenue Agency’s Voluntary Disclosures Program (VDP) provides a statutory framework allowing taxpayers to correct past non-compliance before the CRA initiates enforcement action. A voluntary disclosure involves proactively reporting previously unfiled returns, unreported income, inaccurate filings, or unpaid tax obligations across CRA-administered regimes. When accepted as valid, a disclosure may result in the cancellation of penalties, partial relief of interest, and protection from prosecution, while requiring full payment of underlying tax liabilities.
Voluntary disclosure services are beneficial for individuals, corporations, trusts, and estates where historic tax positions expose the taxpayer to penalties, gross negligence assessments, or criminal risk. Common disclosure scenarios include failure to report business or investment income, offshore income or assets like T1135 form or T1134 form, payroll source deduction deficiencies, GST/HST under-remittances, and late or missing information returns. Disclosures may also arise from complex accounting issues such as income recognition errors, misclassified expenses, or incorrect treatment of taxable benefits.
A frequent misconception is that voluntary disclosure is a purely administrative filing that can be addressed after CRA contact or informal inquiry. In practice, eligibility depends on strict statutory criteria, including voluntariness, completeness, and timeliness. Once the CRA initiates compliance action or obtains specific information, disclosure relief may be limited or unavailable. TaxShield Law applies a disciplined legal and accounting analysis to assess eligibility, structure disclosures strategically, and preserve access to penalty and interest relief under the VDP framework.
TaxShield Law conducts a detailed review of prior filings, financial records, and compliance history to determine whether a disclosure qualifies as voluntary under CRA administrative policy. This assessment evaluates exposure to penalties, interest, and prosecution while identifying disclosure risks arising from partial compliance or prior CRA contact.
We determine whether an application should be positioned under the unprompted or prompted disclosure stream, assessing the impact on penalty cancellation and interest relief. Strategic positioning is informed by the nature of the non-compliance, evidentiary support, and the CRA’s enforcement posture.
Our team prepares comprehensive disclosure submissions that accurately describe the non-compliance, reconcile financial discrepancies, and align accounting records with statutory tax treatment. Submissions are structured to meet CRA completeness requirements while maintaining disciplined issue framing.
TaxShield Law works with accounting professionals to ensure that amended returns, schedules, and supporting documentation are internally consistent, defensible, and responsive to CRA review standards. This includes reconciliation of income, expenses, source deductions, and indirect tax calculations.
We act as authorized legal representatives throughout the disclosure process, managing all communications with the CRA, responding to follow-up inquiries, and addressing requests for clarification while controlling the scope of information disclosure.
TaxShield Law provides voluntary disclosure representation grounded in a precise understanding of the CRA’s Voluntary Disclosures Program, its administrative policy, and the statutory framework governing penalties, interest relief, and prosecutorial discretion. Voluntary disclosures are not assessed solely on numerical accuracy; they are evaluated on eligibility, completeness, timing, and credibility. Our approach focuses on legally structuring disclosures to satisfy CRA criteria while managing exposure arising from prior non-compliance, audit risk, and enforcement thresholds.
Our practice integrates tax law analysis with technical accounting review to ensure that disclosure submissions are internally consistent, reconciled across reporting periods, and aligned with statutory tax treatment. Many disclosure applications fail or receive reduced relief due to inadequate issue framing, unsupported assumptions, or inconsistent financial documentation. TaxShield Law applies disciplined legal oversight to disclosure narratives, evidentiary support, and program classification to preserve access to penalty cancellation and interest relief under the VDP framework.
As legal counsel, we provide the benefit of solicitor–client privilege throughout the disclosure process, allowing sensitive compliance issues to be assessed and addressed without premature exposure. We manage all CRA communications, control the scope of information provided, and respond strategically to follow-up inquiries to prevent disclosure drift or adverse reassessment consequences. TaxShield Law’s structured methodology ensures that voluntary disclosures are positioned as corrective compliance measures rather than enforcement-driven admissions, protecting taxpayer rights while achieving durable resolution with the CRA.
Our Experts
Partner, Senior Vice President Assurance & National Leader Public Companies
1-877-251-2922
Sumit.garg@sgaglobe.com
Partner, Senior Vice President Assurance & National Leader Public Companies
1-877-251-2922
Sumit.garg@sgaglobe.com
Partner, Senior Vice President Assurance & National Leader Public Companies
1-877-251-2922
Sumit.garg@sgaglobe.com
Partner, Senior Vice President Assurance & National Leader Public Companies
1-877-251-2922
Sumit.garg@sgaglobe.com
Why Choose TaxShield Law for Voluntary Tax Disclosures?
Our services combine tax, accounting, and legal solutions all in one place.
Our team includes lawyers and accountants having experience in tax litigation and accounting.
Our team is part of national organizations like the Canadian Tax Foundation (CTF), Society of Trust and Estate Practitioners Canada (STEP Canada), Estate Planning Council of Canada, Chartered Professional Accountants of Canada (CPA Canada), CPA Ontario, The Advocate Society (TAS), Toronto Lawyer Association (TLA, Conference for Advanced Life Underwriting (CALU), Law Society of Ontario (LSO), Ontario Bar Association, the Canadian Bar Association, Peel Law Association (PLA), Halton Law Association (HLA), Estate Planning Council of Toronto, Estate Planning Council of Mississauga.
Our professionals bring over 15 years of experience in tax and law.
Our experienced team has completed advanced tax courses, including the CPA Canada In-Depth Tax Course and the Trust and Estate Practitioner course, to provide in-depth tax advice to our clients.
We attend workshops and seminars from bodies like CPA Canada, STEP Canada, CALU, Canadian Tax Foundation (CTF), The Advocate Society (TAS), Toronto Lawyer Association (TLA), Law Society of Ontario (LSO), Estate Planning Council of Canada, and Mississauga (EPCM).
Our professionals collaborate to provide comprehensive advice on accounting, tax, and legal matters, eliminating the need for multiple experts.
We proudly partner with reputable industry associations and global tax networks, delivering best-in-class expertise with every consultation.