Regarding the deductibility of professional fees incurred in connection with a voluntary disclosure of undisclosed foreign investments, CRA stated:
[P]rofessional fees incurred to make an application under the VDP are not deductible under paragraph 60(o). However, once the CRA has informed the taxpayer that it will be reviewing the income or the tax payable of the taxpayer under the VDP … the professional fees incurred by the taxpayer from that time onward in support of the taxpayer’s position are deductible under paragraph 60(o) … .
CRA went on to indicate that professional fees incurred in applying under the VDP are not deductible.