According to a report in the September 30, 2010 Globe & Mail, CRA has received information on approximately 1,800 Swiss bank accounts held by Canadians. The information was uncovered as part of a French investigation into information related to HSBC’s Geneva office. The French authorities were provided the information by a former employee at that office.
Despite the fact that CRA has received this information, it is possible that these Canadians can still file a voluntary disclosure if they have not reported any income earned in the account or if they have failed to report foreign assets worth more than $100,000. Until CRA contacts the account-holders, it would be difficult for CRA to argue that the disclosures were not voluntary. This would also be consistent with CRA’s past treatment on voluntary disclosures that were filed in response to news of the acquisition of taxpayer information; one such example is CRA’s pursuit of eBay powersellers.