Insights

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...

Reassessment Following an audit of leveraged acquisition financing and subsequent refinancing transactions, the Canada Revenue Agency reassessed multiple taxation years and denied a portion of the com...

Executive Summary Companies that grow through leveraged acquisitions, refinancing strategies, or complex financing structures eventually encounter the same sequence: CRA audit, reassessment, and dispu...

Reassessment The Canada Revenue Agency reviewed a corporate restructuring undertaken as part of a long-term succession plan.

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...