The Strategic Choice After Reassessment
Comparing the CRA’s self-adjudication stage with independent oversight in appeal
Insights
A tax opinion answers a narrower question than most readers assume. Some of the limits are written into the document — in its assumptions, its scope section, its definitions paragraph, and its date....
A tax plan is moving toward implementation. The tax opinion has been delivered. The first question is whether the filing position is defensible. A tax opinion may answer that question and stop...
A company receives a CRA reassessment after prior planning work and tax opinions supported the transactions or filing positions. The company believes the core risk has already been addressed. The...
Key Takeaways The decisive failure in Zhang v. HMK was not mechanical. The CRA lost control of its ability to change the outcome after it accepted a settlement proposal. The taxpayer preserved...
By the time the CRA issues the reassessment, the record is already taking shape. During the objection, the CRA will reinforce its interpretation of the facts and how they apply. That view appears in...
Key Takeaways The reassessment shows the financial exposure. What moves forward depends on how the taxpayer frames the dispute in the Notice of Objection. In this case, the taxpayer’s Notice of...