Revenue Canada Questions & Answers from Conference Day

Are you still allowed to make a voluntary disclosure if you have received an Educational Letter and/or an Intent to Audit Letter?

CRA Response

Yes, you are still eligible to participate in the Voluntary Disclosure Program if you have received an Educational or Intent to Audit Letter.

Are auditors allowed to enter a place a business unannounced? (i.e. as part of our unannounced visits mentioned in the zapper section of the presentation)

CRA Response

Yes, an authorized person may enter into any premises or place where business is carried on, at all reasonable times. Prior authorization is only required where the premises is a dwelling-house.

Section 231.1 of the ITA and section 288 of the ETA permit authorized persons to perform unannounced visits to business premises, require any person on the premises to assist, examine property and processes, and examine and copy documents for the purposes of an inspection, audit or examination. Subsections 231.1(2) ITA and subsection 288(2) ETA provide, however, that if the business premises are located in a dwelling house, the authorized person may only enter with the occupant’s consent or under the authority of a search warrant issued under subsection 231.1(3) ITA or subsection 288(3) ETA.

Unannounced visits will be conducted in a way to keep disruptions of normal business operations to a minimum. All our authorized persons will be carrying an RC121A, Authorization Card, which outlines their authority and identifies them by their signature and picture. Every reasonable effort will be made to safeguard the confidentiality of taxpayer information at all times. It is our expectation to receive reasonable assistance from the business owner or a responsible person at the business during unannounced visits. If they refuse to cooperate and provide requested information, a compliance order will be issued.

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