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 - 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...
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...
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...