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Wayne Bewick, CPA, CA, CPA (Illinois) Partner, Expatriate Tax
1-416-214-7833 x 101  
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Current VDP guidelines allow Canadians who know they have made mistakes on their previous tax returns, from at least one year prior, to come forward and notify the Canada Revenue Agency (CRA) of their misfiled documents. They can then make the appropriate changes to the information without fear of prosecution. The proposed changes would drastically change these policies, including:


  • Cracking down on major cases of non-compliance and providing less relief in such cases
  • Adding payment of taxes owed as a condition to qualify for the VDP
  • Canceling VDP relief for any applications that are found to be incomplete due to willful misrepresentation
  • Making corporations with more than $250 million in gross revenue and/or any whose application involves transfer pricing, excluded from VDP relief
  • Changes the calculation of interest relief that accepted applications are eligible for
  • Ending VDP relief for applications involving proceeds from criminal acts  

The new program will also place applicants in one of two categories:

1) the general program, which allows full penalty relief and partial interest relief, or

2) the limited program, for cases of major non-compliance usually citing willful negligence and fault on the part of the taxpayer, which would only qualify the applicant for some reduced relief.

To fully understand the impact of these proposed changes on your tax strategy, please visit the CRA’s website or connect with a Trowbridge professional for personalized consulting and solutions at This email address is being protected from spambots. You need JavaScript enabled to view it.

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TROWBRIDGE Professional Corporation is a Canadian accounting firm that specializes in international tax services including a wide range of corporate and expatriate tax services to Canadian and foreign-based individuals and corporations. TROWBRIDGE is an independent member of the Global Tax Network (GTN).

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