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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.
Counter Sphere 1 Image, with “CRA Reassessments Behave Like Capital Events” title text, Counter Tax Litigators LLP: strategic leadership in complex CRA disputes.

CRA Reassessments Behave Like Capital Events

Nov 24, 2025 10:15:24 AM - Key Takeaways CRA’s incentive design produces earlier, larger, and more persistent reassessments. The Large Corporation Rules convert those assertions into temporary capital constraints. For executive...