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A CRA reassessment tests something different from the original tax opinion.

Tax Court of Canada decision on CRA settlement after reassessment, showing how accepted settlement terms may not end the dispute when CRA and DOJ continue pulling the file back. (Zhang v HMK)

A CRA reassessment and dispute do not start from a neutral position. They shape the dispute, now and later. This article explains how the record develops and the impact on teh range of outcomes.

CRA reassessment and notice of objection. Large corporation regime. How a failure to define the dispute can stop an appeal early or narrow what can be argued later.

Filing a Notice of Objection places part of the dispute on the record before it is treated as final. That record shapes how the matter is assessed and what can still be changed.

Decisions made after a CRA reassessment form the dispute record before they are recognized as final. That record shapes what can be said, changed, and defended later.