The CRA recently clarified its policy on no-name voluntary disclosures in a press release dated October 1, 2005. In general, a voluntary disclosure can be made on the basis of identifying the taxpayer or on a no-names basis. Where a taxpayer is identified immediately, then they are protected from any subsequent investigations or contact by the CRA. On a no-names basis, however, some advisors were unclear as to whether there was this protection from penalties when the name had not been given. The CRA has clarified its policy. The taxpayer is protected on a no-names basis for 90 days from the time the initial submission has been made. Essentially, the initial date for the voluntary disclosure on a no-names basis is either the date of receipt by a CRA Tax Services Office of a written voluntary disclosure submission or the receipt of a completed taxpayer agreement form (VDP-1).
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