Publication Update: Corporate Residence Disputes and Strategies

Counter Tax Litigators LLP has contributed an updated chapter on Corporate Residence Disputes and Strategies, published by Thomson Reuters in its Tax Disputes & Resolution Centre.

Corporate residence remains a recurring source of dispute between taxpayers and the Canada Revenue Agency, particularly as business operations, governance structures, and cross-border management practices continue to evolve. The updated chapter addresses how corporate residence issues are analyzed and litigated in Canada, with attention to recent jurisprudence, administrative positions, and emerging fact patterns.

The chapter reflects developments in the law as of 2023 and draws on practical experience in advising and litigating corporate residence disputes involving Canadian and multinational groups.

What the chapter covers

The updated chapter examines:

• The application of the central management and control test in modern corporate structures

• The impact of remote management and COVID-era operational changes

• Common evidentiary and strategic issues that arise in corporate residence disputes

• Practical considerations for managing and resolving residence-based reassessments

Access

The chapter is available through Thomson Reuters.

For readers seeking Counter’s current, maintained reference on this topic, see:

Foundations: Corporate Residence in Canadian Tax Disputes