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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 “Control and Economic Reality in Cross-Border Dividend Disputes” title text, Counter Tax Litigators LLP: disciplined litigation for critical tax disputes.

Nov 24, 2025 12:27:21 PM - Key Takeaways Inconsistent cross-border descriptions created tension between the structure’s design and its economic reality. Risk and benefit flowed to different entities across jurisdictions, shapin...

Background Pattern 2 with Strategy Insights text - Shaping CRA Audit Outcomes Before Reassessment, trusted representation for complex, high-stakes tax disputes.

Feb 21, 2025 6:49:16 PM - This article is part of CFO Tax Dispute Insights, Counter Tax Litigators LLP’s executive series delivering strategic guidance to private businesses and CFOs on navigating high-stakes CRA disputes, rea...

Background Pattern 2 with Caselaw Insights text - Hidden Tax Risks in Corporate Life Insurance, strategic tax dispute navigation with deep legal expertise by Counter Tax Litigators LLP.

Feb 11, 2024 7:30:00 AM - Executive Summary A recent ruling by the Federal Court of Appeal in Gestion M.-A. Roy Inc. v Canada, 2024 CAF 16, underscores a growing risk in corporate tax planning: life insurance premiums paid by ...

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

Strategy and Outcomes

Analysis circulated periodically.

Control and Economic Reality in Cross-Border Dividend Disputes

Shaping CRA Audit Outcomes Before Reassessment: Audit Escalation Risk Matrix

Hidden Tax Risks in Corporate Life Insurance

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