Risk
CRA disputes operate at the level of judgment, not mechanics.
When a position is challenged, management decisions drive what follows.
Management’s First Conversation with the Board in a CRA Dispute
Why the initial framing matters before the dispute takes shape.
Ownership
Responsibility ultimately rests with executives.
The position taken and the order of decisions shape the outcomes available.
Insights
February 06, 2026 - Key Takeaways The appeal failed because the parties continued after the win path had closed. The hearing created no real opportunity or upside. The case continued without a clear stop-point, turning...
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...
February 06, 2026 - Keybrand Foods Inc. v. HMQ, shows how interest-deductibility disputes, and others like them, are shaped after reassessment as the objection record crystallizes the explanation of the business...
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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.