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.