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CRA’s Voluntary Disclosures Program is materially more accessible under the rules in effect for applications received on or after October 1, 2025. This 2026 guide explains prompted and unprompted applications, penalty and interest relief, T1134/T1135 and GST/HST disclosures, eligibility, documentation periods and the risks of getting the process wrong.
CRA refused further relief from a T1135 late-filing penalty, relying partly on the very failure the taxpayers were asking relief for. On judicial review of that refusal — not of the penalty assessment itself — the Federal Court in Kaur v. Canada (Attorney General) found the reasoning circular and sent the request back to CRA for redetermination. The Court did not cancel the penalty, and CRA may still refuse relief. Here’s what the decision establishes for anyone facing a T1135 penalty or a refusal of relief.
In Liu v. The King, 2026 TCC 126, the Tax Court struck specific paragraphs from the Crown’s pleadings that advanced a Foreign Accrual Property Income (FAPI) basis..