Insights

Reassessment The Canada Revenue Agency reassessed multiple taxation years and challenged the allocation of income between the Canadian management company and offshore fund entities.

Key Takeaways In recent reversals, the FCA has moved beyond individual provisions to assess how the broader tax regime is meant to function. Predictability now depends less on technical wording and mo...

Reassessment The Canada Revenue Agency reassessed multiple taxation years and challenged the deductibility of management fees charged within the platform.

Key Takeaways Subsection 165(1.11) of the Income Tax Act requires a large corporation to specify in its Notice of Objection the issues, relevant facts, and relief sought. Bakorp Management Ltd. framed...

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 fai...

Key Takeaways The appeal failed because the parties continued after the win path had closed. The hearing created no real opportunity or upside. The case continued without a clear stop-point, turning t...

In large-corporation CRA disputes, the period immediately following reassessment is defined by unresolved conditions. Information is incomplete. Interpretations remain unsettled. Exposure cannot yet b...

Keybrand Foods Inc. v. HMQ, shows how interest-deductibility disputes, and others like them, are shaped after reassessment as the objection record crystallizes the explanation of the business situatio...

Key Takeaways CRA recharacterization does not apply where arm’s length pricing remains available. Courts distinguish pricing disputes from disputes over transaction structure. The objection record set...