Despite wide speculation of significant changes, no substantive revisions were included in the Canada Revenue Agency’s (“CRA”) long-awaited updated information circular (“IC”) on its voluntary disclosures program (“VDP”). At a public presentation on December 1, 2015, CRA officials indicated that an amended and clarified VDP IC would be released in 2016, but no new IC was issued.

On December 8, 2016, the “Report on the Voluntary Disclosures Program” by the CRA’s newly established Offshore Compliance Advisory Committee was issued. That report recommended a number of substantive changes to the VDP. However, the revised IC, released on January 13, 2017, had only one procedural change: all voluntary disclosures must be submitted either electronically or by mail to the Shawinigan-Sud National Verification and Collections Centre. Other than a few other minor consequential and stylistic revisions, no other changes were announced. The effects of these minor changes, if any, remain to be seen.

Substantive changes are likely on the horizon, which we anticipate may restrict both the availability and the benefits of future voluntary disclosures. Anyone with tax omissions, including undisclosed income, who could take advantage of the VDP, should not delay. Remember the adage: The opportunity of a lifetime must be seized within the lifetime of the opportunity.