CRA’s Related Party Initiative

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.

This insight explains how management's initial framing of a CRA dispute with partners, lenders, and boards will shape stakeholders' evaluation of management's performance.

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.