Insights

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...

The CRA has issued its final audit position and has issued, or is about to issue, the notice of reassessment. The dispute is now visible. The immediate question is what happens next. Most teams focus ...

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...