DioGuardi Protected Disclosure - Special Protection and Privilege

DioGuardi Protected Disclosure - Special Protection and Privilege - 4.8 out of 5 based on 12 votes

( 12 Votes )

“The Canada Revenue Agency’s Voluntary Disclosure program is not adequate protection”.

- Paul DioGuardi, Press Statement : Unprecedented database leak of names and particulars of offshore account holders exposes legitimate Canadian taxpayers to dangerous scrutiny, 
April 4, 2013.

In 2004, DioGuardi Tax Law pioneered the concept of Tax Amnesty -  a truly Protected Disclosure of unfiled tax years and/or unreported income. The Tax Amnesty label was quickly adopted by lawyers, accountants, and any one else who offers assistance in resolving issues with the CRA, and applied to the CRA’s Voluntary Disclosure program, (VDP).

But a Voluntary Disclosure and a Protected Disclosure are not the same. Here’s why:

A Voluntary Disclosure, if accepted by the CRA, offers protection against prosecution and penalties for failure to file tax returns, or failure to report income. Interest on tax arrears is also applied at reduced rates. Your application and your returns are reviewed by CRA auditors, in advance of approval of your VDP, who have the discretion to expand their audit to as many years and tax accounts as they choose in order to verify your worthiness of acceptance under the VDP. There’s a huge risk that your disclosure won’t be approved as submitted. At which point the CRA is already in possession of enough information to launch a criminal investigation and then prosecute, impose onerous penalties, and charge interest at the full rate, back-dated to when your returns ought to have been filed. And once you submit your VDP, all your cards are on the table. There’s no drawing back.

The DioGuardi Protected Disclosure, as introduced in 2004, begins with the protection of solicitor-client privilege and only engages in the process of the VDP if and when it is determined that there scrutiny of a CRA audit presents no risk to you and your financial information. If risk is identified, DioGuardi considers more effective legal strategies to present your tax returns to the CRA and limit the scope of any ensuing audit or investigation. This Protected Disclosure ensures you retain the benefit of solicitor-client privilege until your tax matter is resolved.

Accountants and specialists in tax debt resolution cannot offer the protection of privilege.

Since 2004, DioGuardi has represented more than 8,000 taxpayers in their tax matters. This library of case files is unequalled by any independent tax law practice in Canada.  The collective learning from this library of files is made accessible and affordable to the ordinary taxpayer only by DioGuardi.

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