The practical taxman cometh

The first board conversation in a CRA dispute happens before clarity. This insight explains how early framing shapes control, narrows options, and influences how boards judge management under pressure.

Redpath shows how transfer pricing disputes can shift late. Strategic venue choice counters systemic advantage and protects business strategy.

Quebecor v. HMK underscores that CRA challenges to loss consolidation hinge on interpretation over mechanics and on whether the outcome aligns with Parliament’s intent.

A clear view into how courts choose between competing case theories in tax disputes, and why the business’s real decision environment often shapes the interpretation and outcome.

Wuswig v. HMK confirms that under GAAR, economic substance and credible purpose, not mechanical compliance, determine whether corporate losses will stand.

Analysis of the Husky Energy withholding dispute and how courts chose among competing case theories by aligning structure, operations, and cross-border reporting.