When CRA disputes become executive problems, early framing and decisions carry lasting consequences.
At a certain level, CRA disputes move from mechanics to position and interpretation. CRA Appeals or the Tax Court decide whether management’s position can overturn the reassessment. Boards and auditors later review the judgment management exercised during the dispute.
When tax disputes move beyond mechanics, responsibility shifts to the executives who authorize positions and sequencing.
Early decisions shape whether the reassessment is overturned and how the board evaluates management’s decision-making.
Counter LLP operates in the moments where responsibility concentrates and options narrow.
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December 23, 2025 - A CRA dispute does not begin at the board table. It begins earlier, when a proposal letter signals that CRA will issue a notice of reassessment and management recognizes that a board explanation will...
December 12, 2025 - Key Takeaways The Tax Court’s mandate allows the DOJ and CRA to introduce new alternative theories late in litigation, which can increase cost, delay the litigation timeline, and introduce...
November 25, 2025 - Key Takeaways Loss consolidation transactions attract CRA scrutiny even when they align with Parliament’s design. The mechanical structure rarely drives the dispute – the interpretive record does.
November 24, 2025 - Key Takeaways Penn Ventilator v. HMQ shows how disputes evolve when a transaction supports two viable case theories: one tied to the structure, the other to the business’s economic behaviour. ...
November 24, 2025 - Key Takeaways The mechanics worked, but the Court focused on whether the reorganization produced a real economic loss or merely a paper one. That distinction shaped the GAAR outcome. The decisive...
November 24, 2025 - Key Takeaways Inconsistent cross-border descriptions created tension between the structure’s design and its economic reality. Risk and benefit flowed to different entities across jurisdictions,...
