Featured Insights

Management’s First Conversation with the Board in a CRA Dispute

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...

Strategy and Outcomes

Analysis circulated periodically.

Background Pattern 2 Midnight Blue background with White Text - CRA Audits and Disputes: A New Test of Control and Judgement, unique expertise in overturning CRA reassessments by Counter Tax Litigators LLP.

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...

Background Pattern 2 with Caselaw Insights text - Federal Court Sets Higher Bar for CRA: A Win for Taxpayers in Disputes, unique expertise in overturning CRA decisions by Counter Tax Litigators LLP.

Oct 4, 2024 8:15:00 AM - The Federal Court of Canada’s decision in Onex Corporation v. Canada (Attorney General)[1] highlights a meaningful development for taxpayers challenging the Agency’s discretionary decisions. The FC’s ...

Featured Insights

Management’s First Conversation with the Board in a CRA Dispute

Strategy and Outcomes

Analysis circulated periodically.

CRA Audits and Disputes: A New Test of Control and Judgement

Federal Court Sets Higher Bar for CRA: A Win for Taxpayers in Disputes

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