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Missed T1134 foreign-affiliate filings can create significant penalties even where no additional Canadian tax is owing. This guide explains when CRA’s VDP may help, how T1134 penalties work, what must be reconstructed, and why a complete foreign-affiliate review matters.
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.
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..