What is included in the fee for CRA voluntary disclosure package?
The disclosure application with the corrected filings, a documented chronology of how the failure arose, and representation through to the CRA's decision.
What would make CRA voluntary disclosure package cost more than the standard tier?
Whether income as well as reporting was missed. A late information return is one conversation; unreported income across several years is another.
Is the fee really fixed?
Yes, for the scope quoted. If the scope changes — another year appears, an entity turns up, a certificate becomes necessary — we re-quote before doing the work, so there is never an invoice you have not already agreed to.
Will the CRA accept my disclosure if they have already contacted me?
It depends entirely on what they contacted you about. A disclosure has to be genuinely voluntary, and enforcement action relating to the matter you want to disclose can put the programme out of reach. A general reminder letter is not the same thing as an enquiry into the income you are proposing to report. So the first piece of work on any disclosure is establishing where you stand before anything is submitted, because a rejected application has told the CRA what it wanted to know while giving you nothing back. Bring the correspondence and we will read it first.
How much does a voluntary disclosure package cost?
It is quoted in writing before the work starts, and the number of years is only part of what sets the figure. Most of the effort is evidential: rebuilding income from records that may sit with an institution in another country, establishing when and how the failure began, and writing a chronology the CRA can follow without asking. Two disclosures covering the same years can differ substantially on that basis alone. We read the file, tell you what the application involves, and price the correction of the filings alongside it.
Does the fee cover every year I have to correct?
The written scope names the years, so you can see exactly what is inside it. Which years those are is a judgement made at the start, because a disclosure has to reach back far enough to be complete: an application correcting part of the failure and not the rest is not really a disclosure at all. If work on the file turns up a year nobody knew about, we tell you what adding it involves and re-quote before doing it. Nothing is filed for a year you have not agreed to include.
Will I still have to pay the tax I owe?
Yes. A disclosure corrects the filings, and the tax that follows from them remains payable together with interest on it. Relief, where it is available, goes to penalties and in some cases to part of the interest, and it is granted at the CRA's discretion rather than as of right. Anyone who tells you the outcome in advance is guessing. What you can control is the quality of what you put in front of them: complete filings, a chronology that explains itself, and figures that are properly supported. That is what the engagement is for.
What if I cannot find records for the earlier years?
That is the normal starting position and it is not a reason to abandon the disclosure. Records can usually be rebuilt from bank and brokerage statements, from the institution holding the account, and from correspondence you still have somewhere. Where a figure genuinely cannot be established, we say so in the application and set out the basis on which it has been estimated, rather than presenting a reconstruction as though it were a record. An estimate that explains itself is far better received than a precise-looking figure with nothing behind it.
How long does the CRA take to decide a disclosure?
Longer than most people expect, and it varies with the complexity of what has been disclosed and the workload of the office handling it. We do not quote a period, because we cannot control it, and a firm date offered at the outset is one you would be entitled to hold against us. What we do commit to is carrying the correspondence through to the decision: acknowledgements, requests for further information, and the assessment or reassessment that follows, all handled inside the engagement rather than billed as it arrives.
How do I report foreign income on a Canadian return?
You report foreign income in Canada by type and in Canadian dollars. Foreign employment income, interest, dividends, rent, pension and capital gains each go on the line for that kind of income, converted at the rate for the day of the transaction or an acceptable average, with the gross amount reported and the foreign tax withheld claimed as a credit rather than netted off. Holding foreign property above the cost threshold adds the foreign income verification statement, which is a separate filing. See the T1135.
What has to be reported on a T1135?
Specified foreign property held by a Canadian resident where the total cost exceeds the threshold at any time in the year: funds in foreign bank accounts, shares of non-resident corporations — including those held in a Canadian brokerage account — foreign real estate other than personal-use property, debts owed by non-residents, interests in foreign trusts, and foreign life insurance. Property inside a registered plan is excluded, as is property used in an active business. It reports property, not income. See the T1135.
