In a January 21, 2016 Technical Interpretation (2016- 0625731C6, Grondin, Yves), CRA noted that the cost to make a Voluntary Disclosure is not deductible under Paragraph 60(o). However, where income is earned from a business, the cost to make a Voluntary Disclosure may be deductible pursuant to Paragraph 20(1)(cc). 

From the point in which CRA informs the taxpayer that it accepts the Voluntary Disclosure and that it will revise the income or tax liability under the program, professional fees incurred to assert the claim will generally be allowed pursuant to Paragraph 60(o). 

For further information see VTN Monthly Tax Update Seminar, Issue No. 418