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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...
Nov 25, 2025 12:57:45 PM - Key Takeaways Loss consolidation transactions attract CRA scrutiny even when they align with Parliament’s design. The mechanical structure rarely drives the dispute – the interpretive record does. Bus...
Nov 24, 2025 1:27:15 PM - Key Takeaways The mechanics worked, but the Court focused on whether the reorganization produced a real economic loss or merely a paper one. That distinction shaped the GAAR outcome. The decisive batt...
Nov 3, 2025 5:34:33 PM - Key Points CRA can now compel sworn questioning. The Income Tax Act authorizes auditors to require oral testimony under oath during audits, bringing executives directly into the record. Early question...
Oct 29, 2025 7:15:00 AM - Key Takeaways CRA challenges often evolve from mechanical to interpretive tests. The decisive factor is not a structure’s mechanics but whether its interpretive elements hold up under scrutiny. Meetin...
Sep 3, 2025 4:44:53 PM - This article appeared in Thomson Reuters’ Tax Disputes & Resolution Centre, alongside leading resources on managing complex tax controversies.
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