Taxpayer relief provisions and voluntary disclosures

If you are not satisfied with the outcome of a decision made under the taxpayer relief provisions or the voluntary disclosures program because your request was denied or only partially approved, you can make a written request for a second review of the decision. Your request should include your reasons for asking for a review and all the relevant facts and documentation. Send your request to the Director of your tax services office. You can get the address and phone number in the government section of your telephone book.

During the second review, a director, designated manager, or committee impartially reviews the original decision. We let you know by letter the results of the review.

Judicial review

If you feel that discretion was not properly exercised during the CRA's review of your request for relief, you can apply to the Federal Court for a judicial review. The Federal Court does not overturn CRA decisions; its review is restricted to determining whether the CRA has exercised its discretion in a reasonable and fair manner. If the Federal Court rules that discretion was not exercised in a reasonable and fair manner, it refers the request back to the CRA for reconsideration.

For more information on the judicial review process and how to apply, phone the Registry of the Federal Court office nearest you. You can get the phone number in the government section of your telephone book.

For more information, see the following publications:

• IC07-1 Taxpayer Relief Provisions
• G500-3-2-1 Cancellation or Waiver of Penalties and Interest
• IC00-1R Voluntary Disclosures Program