CRA targeting restaurants

Some tax disputes persist even when the outcome is inevitable, and litigation leads to greater sunk costs without any opportunity for recovery.

After a CRA reassessment, management makes decisions under unresolved conditions. This is not a failure of diligence; it is the normal operating environment.

Keybrand shows that when a dominant explanation takes hold, later advocacy is either constrained or given room to operate.

The first board conversation in a CRA dispute happens before clarity. This insight explains how early framing shapes control, narrows options, and influences how boards judge management under pressure.

Redpath shows how transfer pricing disputes can shift late. Strategic venue choice counters systemic advantage and protects business strategy.

Quebecor v. HMK underscores that CRA challenges to loss consolidation hinge on interpretation over mechanics and on whether the outcome aligns with Parliament’s intent.