The Strategic Choice After Reassessment
Comparing the CRA’s self-adjudication stage with independent oversight in appeal
Jennifer Mak
Partner
Jennifer resolves tax controversies with a holistic view to deliver the best overall result.
.png?width=400&height=400&name=CT-How_Can_We_Help-22_july_NewGraphic_b(small).png)
Insights
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....
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...
A CRA Notice of Reassessment sets out the Agency’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...
Executive Summary Companies that grow through leveraged acquisitions, refinancing strategies, or complex financing structures eventually encounter the same sequence: CRA audit, reassessment, and...
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...
A CRA dispute begins when CRA issues its reassessment. Management’s first test begins when it explains it to directors, shareholders, lenders, investors, or partners. The structure varies. The...