Executive Summary Companies that grow through leveraged acquisitions, refinancing strategies, or complex financing structures eventually encounter the same sequence: CRA audit, reassessment, and dispu...
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 fai...
In large-corporation CRA disputes, the period immediately following reassessment is defined by unresolved conditions. Information is incomplete. Interpretations remain unsettled. Exposure cannot yet b...
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 dynamic...
The CRA no longer relies on blunt audit tactics to detect offshore non-compliance. It operates a layered system; data-driven, globally integrated, and increasingly predictive. Most taxpayers facing of...
Key Takeaways for Non-Parties Declining involvement is the default, standard, and strategic approach. DoJ and CRA inquiries post-audit do not create a legal obligation to respond. Written communicatio...
You increase the odds of getting the desired outcome when you give effective discovery answers. Here are some tips to help you.
Guest: Peter Aprile
Tax disputes with the Canada Revenue Agency (CRA) present a complex challenge for individuals and businesses alike. Understanding the interplay between audit, objection, appeals, and collections proce...
The Canada Revenue Agency (“CRA”) has assessed a number of taxpayers who have participated in the detax schemes. In addition, the CRA has imposed 50% subsection 163(2) gross negligence penalties. We t...
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