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      • Tax Dispute Insights

        Clear insight into how complex CRA disputes unfold — helping private-company executives navigate risk, evidence, and resolution with confidence.

      • Canadian Institute for Tax Controversy Studies

        An independent research institute examining the structure, governance, and performance of Canada’s tax-controversy system.

  • About Us
    • How Disputes Work
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      • Tax Dispute Insights

        Clear insight into how complex CRA disputes unfold — helping private-company executives navigate risk, evidence, and resolution with confidence.

      • Canadian Institute for Tax Controversy Studies

        An independent research institute examining the structure, governance, and performance of Canada’s tax-controversy system.

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      Featured Insights

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    • Featured
      • Tax Dispute Insights

        Clear insight into how complex CRA disputes unfold — helping private-company executives navigate risk, evidence, and resolution with confidence.

      • Canadian Institute for Tax Controversy Studies

        An independent research institute examining the structure, governance, and performance of Canada’s tax-controversy system.

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      • Tax Dispute Insights

        Clear insight into how complex CRA disputes unfold — helping private-company executives navigate risk, evidence, and resolution with confidence.

      • Canadian Institute for Tax Controversy Studies

        An independent research institute examining the structure, governance, and performance of Canada’s tax-controversy system.

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Featured Insights

Our latest thinking on tax dispute issues and strategies for mid-market business leaders, affluent families, and their advisors.

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Management’s First Conversation with the Board in a CRA Dispute

Management’s First Conversation with the Board in a CRA Dispute

Dec 23, 2025 12:53:35 PM - A CRA dispute does not begin at the board table. It begins earlier, when a proposal letter signals that CRA will issue a notice of reassessment and management recognizes that a board explanation will...

Strategy and Outcomes

Analysis circulated periodically.

Background Pattern 2 with Caselaw Insights text - Federal Court Sets Higher Bar for CRA: A Win for Taxpayers in Disputes, unique expertise in overturning CRA decisions by Counter Tax Litigators LLP.

Federal Court Sets Higher Bar for CRA: A Win for Taxpayers in Disputes

Oct 4, 2024 8:15:00 AM - The Federal Court of Canada’s decision in Onex Corporation v. Canada (Attorney General)[1] highlights a meaningful development for taxpayers challenging the Agency’s discretionary decisions. The FC’s ...

Tax Dispute Insights - The CRA’s Approach to Accommodation Invoice Tax Schemes, strategic tax dispute navigation with deep legal expertise by Counter Tax Litigators LLP.

The CRA’s Approach to Accommodation Invoice Tax Schemes

May 17, 2022 4:57:00 PM - The general trend is that Canada Revenue Agency is disallowing more input tax credits (“ITCs”) for businesses. In addition, the CRA has launched a project to uncover and disallow ITCs they believe rel...

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