Insights

A company receives a CRA reassessment after prior planning work and tax opinions supported the transactions or filing positions. The company believes the core risk has already been addressed. The orig...

Key Takeaways The decisive failure in Zhang v. HMK was not mechanical. The CRA lost control of its ability to change the outcome after it accepted a settlement proposal. The taxpayer preserved flexibi...

By the time the CRA issues the reassessment, the record is already taking shape. During the objection, the CRA will reinforce its interpretation of the facts and how they apply. That view appears in a...

Key Takeaways The reassessment shows the financial exposure. What moves forward depends on how the taxpayer frames the dispute in the Notice of Objection. In this case, the taxpayer’s Notice of Object...

A CRA Notice of Reassessment has been issued. The deadline to file a Notice of Objection is now active. Management is deciding how to respond. At this stage, management can still shape the response. T...

After a reassessment, management begins making decisions before the full facts and positions are clear. They set an initial view of exposure. They identify the assumptions that support it. They decide...

A CRA Notice of Reassessment sets out the CRA’s position and the amount now assessed. The immediate question is what happens next. Most teams treat what follows as a visible problem: the amount assess...

Key Takeaways C&W pursued a time-sensitive equipment rental and took on tax exposure it did not price into the decision When the facts align with the CRA's case theory this clearly, strategy and dispu...

Reassessment Following an audit of a manufacturing acquisition and subsequent operational integration, the Canada Revenue Agency reassessed several taxation years and denied the use of non-capital los...