The Voluntary Disclosure Program and Swiss Bank Accounts

On September 24, 2009, the Canada Revenue Agency (CRA) disclosed that 36 Canadian taxpayers have filed voluntary disclosures related to unreported income earned in Swiss bank accounts. These taxpayers had bank accounts with Swiss bank UBS, who in August, 2009, agreed to disclose the names of its wealthy American clients to the IRS. UBS has yet to come to an agreement with the CRA to disclose the names of any Canadian account-holders.

Given the lack of an agreement with the CRA, Canadian taxpayers who file a voluntary disclosure regarding any unreported income earned in a Swiss bank account should be able to qualify, given they meet all of the criteria for a voluntary disclosure. Until the CRA has received the list of account-holders from UBS, voluntary disclosures related to Swiss bank accounts should qualify as voluntary (subject to any unrelated actions by the CRA).