Thank you.
I would like now to turn to the voluntary disclosure program. It appears on the letter, which is on the CBC website, that you asked the taxpayer to use the voluntary disclosure program.
In the information circular on the voluntary disclosures program, it says that disclosure must be voluntary, and I quote:
A disclosure will not qualify as a valid disclosure…under the “voluntary” condition if the CRA determines:the taxpayer was aware of, or had knowledge of an audit, investigation or other enforcement action set to be conducted by the CRA or any other authority or administration, with respect to the information being disclosed to the CRA….
How can you allow a voluntary disclosure that violates the rules governing voluntary disclosure? The taxpayer who received the letter through KPMG knew that the CRA had suspicions about their activities. In this case, how was the taxpayer able to take advantage of the voluntary disclosures program?