WHEN A TAX DISPUTE BEGINS
Counter Tax Litigators LLP acts for private companies in significant tax disputes.
Typical disputes involve loss utilization following acquisitions, surplus extraction arising from corporate reorganizations, valuation, and other judgment-driven reassessment matters.
When a reassessment creates exposure, early clarity is critical.
Chambers Global · Chambers Canada · International Tax Review
HOW COMPLEX DISPUTES UNFOLD
In judgment-driven disputes, early positions shape the dispute that follows.
Responsibility rests with leadership. Decisions and their rationale determine whether a position withstands review.
The dispute is contained by the strategy adopted, the record created, and the forum in which it is ultimately resolved.
A CRA Notice of Reassessment has been issued. The deadline to file a Notice of Objection is now active. Management is deciding how to respond. At this stage, management can still shape the response....
After a reassessment, management begins making decisions before the full facts and positions are clear. They set an initial view of exposure. They identify the assumptions that support it. They...
A CRA Notice of Reassessment sets out the Agency’s position and the amount now assessed. The immediate question is what happens next. Most teams treat what follows as a visible problem: the amount...
Executive Summary Companies that grow through leveraged acquisitions, refinancing strategies, or complex financing structures eventually encounter the same sequence: CRA audit, reassessment, and...
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...
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...
