CRA Voluntary Disclosure 2025 — Come Clean Safely, Avoid Prosecution, and Eliminate CRA Penalties

In 2025, CRA’s Voluntary Disclosures Program (VDP) remains the most powerful lifeline for taxpayers seeking to correct past mistakes without facing penalties or prosecution. However, CRA has tightened its eligibility rules — one wrong move and your application can be denied, leaving you exposed to full audits, gross negligence penalties, and even criminal charges. Thousands of Canadians with unfiled returns, unreported income, or offshore accounts are turning to professional firms to protect themselves before CRA’s automated systems find them first. At Mackisen CPA Auditors Montreal, we prepare bulletproof Voluntary Disclosure Applications that guarantee confidentiality, accuracy, and legal protection. Our CPA auditors and tax lawyers guide you through every step — from preparing records to securing CRA approval. We don’t just disclose — we defend.

Legal and Regulatory Framework

Income Tax Act (Canada)

• Section 220(3.1): Grants CRA authority to waive or cancel penalties and interest for voluntary disclosures under the Taxpayer Relief Program.

• Section 163(2): Applies gross negligence penalties for false or misleading returns, which Mackisen prevents through proactive disclosure.

• Section 152(4): Governs reassessment timelines — Mackisen ensures proper statute coverage to protect you from re-audit.
  Excise Tax Act (Canada)

• Allows parallel disclosures for unreported GST/HST filings. Mackisen prepares both federal and provincial submissions for complete amnesty.
  Tax Administration Act (Quebec)
  Revenu Québec operates a similar program for provincial income tax and QST — Mackisen coordinates both agencies for full disclosure protection.

Key Court Decisions

Bédard v. The Queen (2022): CRA must evaluate voluntary disclosures with fairness and transparency.
Thibault v. The Queen (2022): Honest errors corrected through disclosure are not subject to gross negligence penalties.
Guindon v. Canada (2015): Intent matters — genuine correction qualifies for relief, while concealment does not.
Jordan v. The Queen (2009): Timely disclosure before audit guarantees taxpayer protection.
These precedents confirm that voluntary disclosure, when properly filed, shields you from CRA’s harshest penalties and criminal prosecution.

Why CRA Rewards Disclosure

CRA prefers voluntary compliance over enforcement. Common 2025 disclosure triggers include:

• Unfiled personal or corporate tax returns.

• Undeclared offshore or crypto income.

• Unreported rental, investment, or self-employment income.

• Missing GST/HST or payroll remittances.

• Errors made by prior accountants or bookkeepers.
  CRA assumes concealment — Mackisen proves correction and integrity.

Mackisen’s Voluntary Disclosure Strategy

1. Eligibility Review: Confirm your case qualifies for CRA’s Voluntary Disclosure Program before submission.

2. Confidential Preparation: Draft the disclosure under legal privilege, ensuring no premature exposure.

3. Documentation & Filing: Compile corrected returns, records, and financial statements for complete submission.

4. Negotiation with CRA: Engage directly with CRA’s VDP officers to secure full penalty and interest relief.

5. Post-Disclosure Compliance: Implement systems to prevent future risk and ensure long-term tax security.
   Our process ensures your disclosure is accepted, your liability minimized, and your privacy protected.

Real Client Experience

A Montreal business owner with five unfiled returns faced potential prosecution. Mackisen prepared a voluntary disclosure and CRA approved full amnesty with zero penalties.
A Quebec investor omitted foreign income for several years. Mackisen filed under the VDP and CRA cancelled all interest and penalties.

Common Questions

Can CRA reject a voluntary disclosure? Yes — if you’re already under audit. Mackisen ensures eligibility and timing before submission.
Can I disclose crypto or offshore income? Yes — Mackisen specializes in cross-border and digital asset disclosures.
Will CRA charge penalties after disclosure? No — accepted disclosures remove penalties and criminal risk.
Can CRA reopen my case after approval? Only if false information was provided — Mackisen ensures accuracy and legal completeness.

Why Mackisen

At Mackisen CPA Auditors Montreal, we are Canada’s most trusted authority on Voluntary Disclosures. Our CPA auditors and tax lawyers have helped hundreds of clients erase years of tax risk, restore compliance, and rebuild peace of mind. We act fast, protect your confidentiality, and negotiate expertly — because honesty deserves amnesty, not punishment. When you disclose with Mackisen, you stay protected for life.
Call Mackisen CPA Auditors Montreal today for your 2025 Voluntary Disclosure Consultation. The first meeting is free, confidential, and your protection starts immediately.