Voluntary disclosures (“VDs”) are permitted for Canadian tax purposes under the Canada Revenue Agency’s (the “CRA”) Voluntary Disclosures Program (the “VDP Program”), and their importance is highlighted by a recent case where the CRA reached back into history to assess a taxpayer prior tax exposure.
CRA Power to Reassess Beyond Limitation Periods
Typically, the CRA can reassess a taxpayer within four years for GST/HST matters and three years for income taxes: see paragraph 298(1)(a) of the Excise Tax Act (the “ETA”); see subsection 152(3.1) of the Income Tax Act (the “ITA”).