Risk
CRA disputes operate at the level of judgment, not mechanics.
CRA challenges the position management has taken and seeks to reassess.
Management’s First Conversation with the Board in a CRA Dispute
Why the initial framing matters before the dispute takes shape.
Ownership
Beyond mechanics, responsibility sits with executive decision-makers.
Management’s position and sequencing set the range of possible outcomes.
Insights
.png?width=496&height=279&name=CRA%20Disputes_Management_Board_First_Conversation%20(Sphere%201%20Purple).png)
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,...