Can I still use the CRA programme after getting a letter?
Relief under the programme is available only while the disclosure is still voluntary, and voluntariness ends once the CRA has begun to act. So the first question on any file that has had contact is what that contact actually was. A general campaign letter, a query about a specific year, and the opening of an examination are not the same thing, and the distinction decides whether the route is open at all. Establish it from the correspondence itself before preparing anything, because a submission made after that point does not attract the relief it was built for.
What is the difference between the general and limited programmes?
They are two tiers of the same programme, giving different relief. The general tier provides penalty relief and partial interest relief. The limited tier provides less, and it applies where the conduct behind the failure was more culpable. Which tier applies depends on how the failure came about, so the analysis is about conduct and circumstances rather than about amounts. That work has to be done before the submission is made, because the tier shapes what the disclosure is asking for, and a submission that asks for the wrong tier invites the reader to settle the question instead.
Does the amount I owe decide which tier I get?
No. The tier turns on how the failure came about, not on how much is owed, which surprises most people who come to this. A large balance arising from a genuine misunderstanding of a reporting obligation sits differently from a small one arising from conduct the filer was aware of at the time. So the preparatory work is evidential rather than computational at the outset, meaning establishing what was known, when, and on what advice. The computations matter a great deal, but they answer a different question from the one the tier depends on.
Will the CRA cancel the interest as well as the penalties?
Under the general tier the relief covers penalties and part of the interest, so interest is reduced rather than removed. That is worth building into the expectation at the outset, because a filer who has assumed the whole balance disappears is surprised at the end by an amount that was always going to remain. It also affects how a multi-year disclosure is planned, since interest accrues on the tax itself and the tax is payable in any event. The shape of the outcome is tax in full, penalties relieved, and interest relieved in part.
I have unreported foreign income, where do I start?
Not with the returns. Two things are settled first: whether the disclosure is still voluntary, which depends on whether the CRA has begun to act, and which tier the facts support, which depends on how the failure came about. Those answers set what is being asked for and how the submission has to be framed. The reconstruction work, meaning account histories obtained, income rebuilt year by year and tax computed, is the larger job in hours and the second job in sequence. Done in the other order it tends to produce a complete file aimed at the wrong tier.
Which years should a voluntary disclosure to the CRA cover?
The scope is set before filing rather than discovered during it. The years to include are the years in which income went unreported or a filing was missed, and the whole set is decided at the outset, because the relief attaches to what is actually disclosed. Leaving a year out to keep the submission tidy creates a file that is complete on its face and incomplete in fact, which is a poor foundation for an account of how the failure came about. Where the records for a year are thin, the answer is to obtain them rather than to drop the year.
Do Canada and the United States share tax information?
Yes, through more than one channel. The treaty has an exchange-of-information article that supports both routine and on-request exchange. Separately, an intergovernmental agreement has Canadian financial institutions identify US-reportable accounts and report them to the CRA, which passes them to the IRS, with the reverse flow for Canadian residents. Most other country pairs use the Common Reporting Standard for the same purpose. See FATCA reporting.
Is moving money between my own accounts in two countries taxable?
Moving your own capital between your own accounts is not itself income, so the transfer is not what creates tax. What can create tax or reporting is the income the money earned before it moved, a foreign-exchange gain on certain holdings, and the reporting obligations the balances themselves trigger — foreign account and asset reports keyed to balances rather than income. Remittances out of some countries also need certification before the bank will send them. See foreign account reporting.
