Paragraph 60(o) of the Income Tax Act (Canada) allows a taxpayer to deduct professional fees “incurred in preparing, instituting or prosecuting an objection to, or an appeal in relation to, an assessment of tax […]”. The CRA recently confirmed that this provision covers professional fees incurred to defend a taxpayer’s position once the taxpayer’s voluntary disclosure is accepted. The CRA noted, however, that professional fees that relate to the filing of the voluntary disclosure are not deductible under this provision.

Link: http://www.thor.ca/wp-content/uploads/2016/05/CRA-Views-2016-0625731C6-Fees-related-to-a-voluntary-disclosure.pdf