Risk
CRA disputes operate at the level of judgment, not mechanics.
When a position is challenged, management decisions drive what follows.
Management’s First Explanation in a CRA Dispute
Early framing shapes how others evaluate management’s judgment
Ownership
Responsibility ultimately rests with executives.
The position taken and the order of decisions shape the outcomes available.
Insights
February 11, 2026 - In large-corporation CRA disputes, management must make consequential decisions immediately after reassessment while information remains incomplete and positions unsettled. This does not reflect a...
February 06, 2026 - In large-corporation CRA disputes, the period immediately following reassessment is defined by unresolved conditions. Information is incomplete. Interpretations remain unsettled. Exposure cannot yet...
December 23, 2025 - A CRA dispute begins when CRA issues its reassessment. Management’s first test begins when it explains it to directors, shareholders, lenders, investors, or partners. The structure varies. The...
November 24, 2025 - Key Takeaways CRA’s incentive design produces earlier, larger, and more persistent reassessments. The Large Corporation Rules convert those assertions into temporary capital constraints. For...
September 19, 2025 - Executive Abstract A CRA dispute unfolds across multiple institutions with different incentives and objectives. After a reassessment is issued, control over the advice and guidance shapes how the...
September 07, 2025 - Peter Aprile, Senior Counsel at Counter LLP, describes three inflection points that define how CRA challenges develop and are resolved. The framework reflects insights drawn from years of...