The Strategic Choice After Reassessment
Comparing the CRA’s self-adjudication stage with independent oversight in appeal
Since 2008, Natalie has dedicated her practice exclusively to resolving tax disputes, providing trusted expertise to private company CEOs and high-net-worth individuals.
Natalie consistently devises innovative litigation strategies, and she has achieved highly favourable outcomes for numerous clients.
Natalie has:
Natalie regularly presents on tax matters and contributes articles, sharing her expertise in tax avoidance, shareholder benefits, and various tax issues. She also offers her insights on different methods to create advantages in tax disputes. And she has developed courses to teach tax litigators about early case assessment, strategy in litigation, and decision science.
Natalie also offers mentorship and coaching to litigation lawyers and rising stars outside of Counter’s team, fostering growth and litigation excellence within the broader legal community.
Natalie’s accomplishments were recognized with the Lexpert Rising Stars: Leading Lawyers Under 40.
This award honours lawyers who have made outstanding contributions in their careers. It is voted on by an advisory panel of leading legal experts.
Natalie was featured in the Society of Decision Professionals’ Member Spotlight for 2022.
The Society of Decision Professionals (SDP), a membership organization dedicated furthering the practice of decision analysis and decision quality. SDP is currently the only certifying body for decision professionals.
Natalie was honored to receive a Fastcase 50 Award in 2020.
Fastcase 50 is an international award that recognizes lawyers, legal technologists, and judges who inspire others in the legal industry through their intelligence, creativity, and leadership.
Comparing the CRA’s self-adjudication stage with independent oversight in appeal
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...