The questioner pointed out under the 10-year limitations period for the Voluntary Disclosure Program, a participating individual with unreported income for 15 years would be exposed to interest and penalties for the first five years. CRA stated:
There are no legislative restrictions to assessing any year if the requirements in the applicable legislation are met. As a result, the CRA will not provide assurances that they will not assess beyond 10 years. We will apply the legislation as it relates to statute-barred years and assess income in the year it was earned.
CRA also noted that its discretion is fettered by legislation.