Capabilities

Engagement begins at reassessment, where leverage shifts

Control is set early — in the record established with the CRA and in how leadership explains the dispute to partners, boards, and lenders.

1 | Rapid Diagnosis and Stabilization 

A reassessment introduces uncertainty before the dispute is fully understood. Rapid diagnosis stabilizes the situation. 

  • classify the dispute and its governing issues
  • frame the working exposure range and the assumptions behind it
  • stabilize positions before they harden into the record

Insight > CRA Reassessment | What Happens Next

2 | Dispute Feasibility & Strategy

Strategic analysis defines the course of the dispute and the target outcome.

  • assess the facts and legal issues that define the case
  • forecast exposure ranges and the uncertainties driving them
  • compare viable resolution paths across negotiation, objection, and court

Insight > The Reassessment Decision Window in a CRA Dispute

 3 | Arena Execution 

After the strategy is set, the dispute moves forward within the chosen arena.

  • advance the matter within CRA review or before the Tax Court

  • manage negotiation dynamics within that environment

  • preserve credibility and leverage as the dispute progresses

Insight > How Courts Decide When a Transaction Can Be Read Two Ways  

4 | Stakeholder Alignment & Reporting

Partners, boards, lenders, and auditors receive disciplined reporting throughout the dispute. 

  • establish the narrative carried to boards, lenders, and auditors

  • maintain disciplined updates as the dispute evolves

  • preserve narrative stability as facts and positions develop

Insight > Management’s First Explanation in a CRA Dispute 


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Governance & Standards > How work is governed

 The Work > The analytical standard behind every output

Insights

Notice of Objection Window | What Carries Forward

Notice of Objection Window | What Carries Forward

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....

CRA Dispute Record Formation | Decisions Made Before Clarity

CRA Dispute Record Formation | Decisions Made Before Clarity

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...

CRA Reassessment | What Happens Next

CRA Reassessment | What Happens Next

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...

Leveraged Growth and the CRA Reassessment Cycle

Leveraged Growth and the CRA Reassessment Cycle

Executive Summary Companies that grow through leveraged acquisitions, refinancing strategies, or complex financing structures eventually encounter the same sequence: CRA audit, reassessment, and...

The Reassessment Decision Window in a CRA Dispute

The Reassessment Decision Window in a CRA Dispute

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...

Management’s First Explanation in a CRA Dispute

Management’s First Explanation in a CRA Dispute

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...

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