Voluntary Disclosures Program

If you’ve made mistakes on your past tax returns or haven’t filed them at all, the CRA’s Voluntary Disclosures Program (VDP) may allow you to come forward, fix those issues, and avoid penalties, reduce interest and prosecution. A Toronto tax lawyer can help you prepare your disclosure properly and negotiate the best possible result with the CRA.

For many taxpayers, voluntary disclosure can mean the difference between manageable repayment and financial crisis.

Eligibility Criteria

The CRA updated the VDP on October 1, 2025. The program now applies to excise duties, fuel charge, luxury tax, underused housing tax, digital services tax, global minimum tax, air travellers security charge, and the softwood lumber export charge.

To qualify under the voluntary disclosures program, the CRA requires that all five of the following conditions are met:

• Voluntary – your disclosure must come before the CRA contacts you. If you’re already under audit or if the CRA is auditing someone connected to you, your disclosure may be rejected.
• Complete – you must come forward with full and accurate information about all past errors. For Canadian income or assets, this normally means providing documentation for the most recent six years. If the disclosure involves foreign income or property, the CRA requires the most recent ten years. In certain cases, we can help limit the years, explain estimates if full records aren’t available, and respond if the CRA requests additional periods.
• Penalty/Interest – the issue you’re correcting must be one where a penalty or interest could apply. This is usually straightforward to meet.
• One Year Past Due – the information you’re disclosing must relate to a taxation year (or GST/HST reporting period) that is at least one year overdue.
• Payment – you must pay the taxes owing in full or arrange a payment plan with the CRA. We can help negotiate that payment plan as part of your disclosure.

Unprompted vs. Prompted

The CRA has two VDP streams:

• Unprompted (General Program): No prior CRA contact. Provides 100% penalty relief and 75% interest relief; and
• Prompted (Limited Program): CRA has already contacted you or received information from third parties. Provides up to 100% penalty relief and 25% interest relief.

In both cases, accepted disclosures are not referred for prosecution, and gross negligence penalties don’t apply on the disclosed issues.

A Toronto tax lawyer at Kirshen Tax Law can assess your eligibility and make sure your application is processed through the Unprompted Program.

Why Work with Kirshen Tax Law?

As experienced Toronto tax lawyers, we’ve submitted hundreds of successful voluntary disclosures and know exactly how to maximize relief while protecting your position. We know exactly what the CRA looks for and how to structure your submission for the best possible outcome.

If you need help finding an accountant to prepare or correct your filings, we can connect you with professionals we trust.

Proven Results: Voluntary Disclosures

We’ve submitted hundreds of successful VDP applications for individuals and businesses, including unreported income, offshore accounts, late-filed GST/HST returns, and missed T1135 forms. In many cases, we’ve secured full penalty relief, partial interest relief, and avoided prosecution. We’ve also succeeded on second-level reviews where initial relief was denied, overturning negative outcomes and getting our clients the relief they deserved.

See examples of successful voluntary disclosures and second-level reviews here.

Book a Free Consultation

Worried about unfiled returns or past tax mistakes? Contact us today for a free consultation with a Toronto tax lawyer. We’ll help you resolve unfiled returns, past errors and omissions with confidence.