What to do next
Get advice before contacting the CRA
Speak to a tax lawyer first. Legal privilege applies to a lawyer's advice in a way it does not to an accountant's working papers, which matters if the exposure could become criminal.
Establish whether the disclosure is still voluntary
The programme requires that you come forward before enforcement action relating to the issue. If a letter has already arrived, the analysis changes and different strategy applies.
Quantify the full exposure across all years and authorities
Federal and, for Quebec residents, provincial. Foreign accounts and assets carry separate reporting obligations with their own substantial penalties, which are often the larger problem.
File complete and accurate disclosure
Partial or misleading disclosure defeats the relief and worsens your position. The point of the programme is completeness.
Frequently asked questions
Will I be prosecuted?
A properly accepted voluntary disclosure can provide relief from prosecution as well as penalties. That protection depends on coming forward first, which is why timing is everything.
Should I use my accountant or a lawyer?
Start with a tax lawyer. Solicitor-client privilege protects the advice; an accountant's file generally is not privileged and can be compelled.
What about foreign accounts?
Foreign asset and income reporting carries its own penalties, often larger than the tax itself. Include everything in the disclosure.
How many years back?
Disclosure is expected to cover all affected years. Establish the full scope before filing anything.
This is general information, not legal advice. Laws vary by location and every situation is different — speak with a qualified lawyer about your specific circumstances.