The CRA has a program that allows taxpayers to come forward and disclose income or property that they had not previously disclosed. In exchange, the CRA commits not to prosecute the taxpayer for criminal tax evasion and usually agrees not to assess penalties and to reduce the interest charges.

Recently, the CRA made significant changes to the voluntary disclosure program, reducing the certainty that taxpayers who make a disclosure will receive the normal relief from penalties and interest. This has made it more important for taxpayers to be strategic and precise when making a disclosure.