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      • Tax Dispute Caselaw & Signals

        Signals from CRA disputes that reveal how outcomes are decided.

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        Independent research focused on the structure and performance of Canada’s tax dispute 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.

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

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      • Tax Dispute Caselaw & Signals

        Signals from CRA disputes that reveal how outcomes are decided.

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        Independent research focused on the structure and performance of Canada’s tax dispute 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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What changes when a CRA reassessment shapes outcomes.

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When a Tax Court Appeal Becomes Cost, Not Opportunity

When a Tax Court Appeal Becomes Cost, Not Opportunity

Feb 6, 2026 11:47:15 AM - Key Takeaways The appeal failed because the parties continued after the win path had closed. The hearing created no real opportunity or upside. The case continued without a clear stop-point, turning...

Strategy and Outcomes

Analysis circulated periodically.

System Advantage and Late-Shifting Positions in Transfer Pricing Disputes Redpath underscores the importance of moving disputes into the arena with appropriate oversight

System Advantage and Late-Shifting Positions in Transfer Pricing Disputes

Dec 12, 2025 4:42:50 PM - Key Takeaways The Tax Court’s mandate allows the DOJ and CRA to introduce new alternative theories late in litigation, which can increase cost, delay the litigation timeline, and introduce litigation ...

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