The Post-Reassessment Decision Window in a CRA Dispute

In large-corporation CRA disputes, management must make consequential decisions immediately after reassessment while information remains incomplete and positions unsettled. This does not reflect a failure of diligence. It reflects the normal operating environment at this stage.

In practice, what happens in the first weeks after reassessment sets the path.

The structure of the large-corporation regime requires management to act:

• Payment positions must be addressed.
• A complete Notice of Objection must be prepared and filed.
• Internal explanations begin to stabilize.
• External audiences such as partners, the board, lenders, or the audit committee are briefed.

Each of these steps requires decisions while uncertainty persists. The regime does not wait for clarity.

Those decisions are embedded in filings, payment choices, and governance communications.

• Payment choices establish the level of exposure management is prepared to carry.
• Draft filings fix the factual and interpretive characterizations the company relies on.
• Early briefings establish the level of escalation management and governance bodies come to expect.

Individually, these decisions appear provisional. Institutionally, they are not. Together, they form the first permanent record. It takes shape and hardens before management or the board treats it as settled.

When the Notice of Objection is filed, that record becomes the reference point and boundary against which later decisions are judged. Management may try to expand or change course, but revision is no longer neutral. Changes require explanation and draw scrutiny, internally and externally.

Structural context

Why decisions made under uncertainty still become the record

Following reassessment, uncertainty is structural. Facts remain incomplete. Interpretive positions are unsettled. Visibility is limited.

Despite this, the regime requires positions to be entered into the formal record through payment decisions, filings, and governance communications.

Management may, in some cases, adjust those positions later. However,  permitted adjustments must reconcile with what was recorded earlier. The cost is not procedural. It is explanatory.

Dispute outcomes are constrained long before resolution. The law has not settled. The permanent record has.

Some management teams see this window only after it has closed. Others use it to frame flexible positions and create a record that becomes stronger when examined.

Under the large-corporation regime, outcomes tend to follow early decisions made under unresolved conditions. At the end of the dispute, attention turns not only to how it was resolved, but to how management set the company’s initial course.