A CRA dispute begins when CRA issues its reassessment.
Management’s first test begins when it explains it to directors, shareholders, lenders, investors, or partners.
The structure varies. The dynamic does not.
Management must describe the issue, estimate exposure, decide who will lead the response, and work within statutory timelines. These pressures arise before a settled view has formed.
By the time others hear about the matter, management has already organized it. That organization defines how risk is understood and where discretion appears to exist.
The first explanation often occurs between the CFO and CEO. It determines how the issue enters the organization.
That description establishes:
Subsequent analysis develops inside that structure. It rarely replaces it.
Those receiving the explanation do not encounter the issue at inception. They encounter it after management has formed a view.
Framing that lacks structure at the outset rarely gains strength later.
When management explains a CRA dispute, the audience is not reviewing technical detail. They are evaluating judgment under pressure.
A proposal letter compresses several decisions into a single window. Management must:
These steps unfold together.
In that window, others assess whether management is:
The first description defines what appears fixed and what appears open. Later analysis develops inside that boundary. When management resets the frame later, the shift often reads as a correction, and credibility erodes.
Disciplined teams separate judgment formation from circulation. Before a formal summary leaves the immediate working group, they align on:
Alignment preserves credibility and flexibility.
When the matter concludes, others will ask whether management shaped the issue at the outset or allowed it to take shape around them.