How is Bozzer v. The QueenI, 2011 FCA 186, affecting voluntary disclosures that exceed ten years? CRA stated:
Voluntary disclosures that cover more than ten taxation years are currently being processed by the Voluntary Disclosure Programs (VDP) offices in accordance with the Federal Court of Appeal decision in Bozzer v. Queen (2011 FCA 186); the limitation period in subsection 220(3.1) of the Income Tax Act provides the Minister with the discretion to waive or cancel interest that accrued within the last ten calendar years, from the year the request was made, notwithstanding the taxation year from which the debt arose. …