Capabilities

Engagement begins at reassessment, where leverage shifts

In judgment-driven disputes, advantage forms early as exposure is recognized, positions align, and issues take shape. Disputes move through four environments: exposure recognition, internal alignment, objection strategy, and tax court strategy.

Exposure Recognition

Reassessments surface exposure and force early judgment about the dispute’s scale and character. Recognizing that exposure early determines how the dispute takes shape. 

 Internal Alignment

When exposure appears, stakeholders form an internal understanding of the dispute. Alignment around that understanding enables concise communication with leadership, limiting noise and disruption. 

Objection Strategy

The objection determines what the dispute is actually about. Issues, assumptions, and arguments become fixed, and the terrain of the dispute is set.

 

Tax Court Strategy

Where leverage improves at the Tax Court stage, the dispute proceeds accordingly. Filing and disciplined litigation shift negotiating leverage. 

Insights

Leveraged Growth and the CRA Reassessment Cycle

Leveraged Growth and the CRA Reassessment Cycle

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The Reassessment Decision Window in a CRA Dispute

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Management’s First Explanation in a CRA Dispute

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