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The Changes & Uncertainty in the New Voluntary Disclosures Program (PT. 1)

Canadian Tax Insights Podcast S01E01

Counter Tax Lawyers and LexisNexis Canada have joined forces to bring you a new tax podcast that is designed to keep accountants and lawyers up to date on the changes that will impact their clients and their practices.

In S01E01, Peter Aprile and Yoni Moussadji discuss the Canada Revenue Agency’s revised Voluntary Disclosures Program which will take effect on March 1, 2018. In particular, the parties discuss how the CRA’s changes will narrow the eligibility criteria and increase penalties, and lead to more VDP disputes. Also, Peter and Yoni speak with Mac Killoran to get a CPA’s perspective on the revised VDP and how the changes might expose CPAs to increased scrutiny, CRA demands for information, and third-party penalties.

If you are a CPA, you can complete our 5-minute online quiz so that you can use your CTI podcast listening to earn verifiable CPD. We’ll even email you a fancy CPD certificate for your records.

Mac Killoran


Mac Killoran, Fruitman Kates LLP

Mac Killoran joined Fruitman Kates in April 2013 to head up the firm’s tax group. Mac specializes in executing strategies to minimize tax and is well versed in corporate tax compliance, partnership tax reporting, personal tax compliance, cross-border, commodity tax (GST/HST), and CRA disputes. Mac prides himself in his ability to offer clients peace of mind knowing that all possible filing positions have been considered without leaving any capital on the table.

Prior to joining the team at Fruitman Kates, Mac worked in mid-market public accounting since graduating university. He also worked at his family business, Weber’s, a well-known Muskoka destination and has acquired core knowledge of the business strategies and communication for small to medium privately owned businesses.

Peter Aprile


Peter Aprile, Counter Tax Lawyers

Peter Aprile is a senior lawyer specializing in tax dispute resolution and litigation. His vision as Counter’s founder and his everyday role at the firm are one and the same: to be an agent of change, uncovering opportunities and developing strategies that achieve more than anyone expected. A creative thinker, Peter studies problems from all different angles to find what others have missed. He’s also convinced that he likes winning more than most people.

Different people describe Peter in different ways. At the CRA and the federal Department of Justice, the word relentless comes up quite a lot. Admittedly, so does the word a**hole – but it’s often said with a certain grudging respect, if not affection. Peter’s clients call him a saint. Well, some of them, anyway. His colleagues describe him as empowering and harddriving, but fair. Peter’s friends call him loyal. His wife describes him as a lot to deal with, but worth it. Peter encourages his young daughter and son to call him “The Big Homie,” though with limited success. His mother describes him with the single word mischievous – before going on to complain that he should call more.

Read Peter’s complete bio →

Yoni Moussadji


Yoni Moussadji, Counter Tax Lawyers

Yoni Moussadji is a tax lawyer who represents individuals and corporations in disputes with the Canada Revenue Agency (CRA). Appearing regularly before the Tax Court of Canada, the Federal Court and the Federal Court of Appeal, he takes pride in negotiating favourable settlements that save his clients time and money while limiting their exposure. 

Enrolling at Osgoode Hall Law School, Yoni actually started out intending to focus on criminal law and become a Crown Prosecutor. But then a fellow student urged him to take a tax law course, explaining it was important to know at least a bit about tax, as it tended to come up everywhere. So Yoni signed up for the course, and in no time he was hooked. The following semester he took as many tax courses as possible.

True to his nature, as a lawyer Yoni is never content to rely on the analysis of others. He constantly pushes the boundaries in his quest for original ideas. He also drums a lot on the edge of his desk – something he does better than most people. But never in court. 

Read Yoni’s complete bio →