Capabilities

Engagement begins at reassessment, where leverage shifts

Control is set early — in the record established with the CRA and in how leadership explains the dispute to partners, boards, and lenders.

1 | Rapid Diagnosis and Stabilization 

A reassessment introduces uncertainty before the dispute is fully understood. Rapid diagnosis stabilizes the situation. 

  • classify the dispute and its governing issues
  • frame the working exposure range and the assumptions behind it
  • stabilize positions before they harden into the record

Insight > CRA Reassessment | What Happens Next

2 | Dispute Feasibility & Strategy

Strategic analysis defines the course of the dispute and the target outcome.

  • assess the facts and legal issues that define the case
  • forecast exposure ranges and the uncertainties driving them
  • compare viable resolution paths across negotiation, objection, and court

Insight > The Reassessment Decision Window in a CRA Dispute

 3 | Arena Execution 

After the strategy is set, the dispute moves forward within the chosen arena.

  • advance the matter within CRA review or before the Tax Court

  • manage negotiation dynamics within that environment

  • preserve credibility and leverage as the dispute progresses

Insight > How Courts Decide When a Transaction Can Be Read Two Ways  

4 | Stakeholder Alignment & Reporting

Partners, boards, lenders, and auditors receive disciplined reporting throughout the dispute. 

  • establish the narrative carried to boards, lenders, and auditors

  • maintain disciplined updates as the dispute evolves

  • preserve narrative stability as facts and positions develop

Insight > Management’s First Explanation in a CRA Dispute 


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Governance & Standards > How work is governed

 The Work > The analytical standard behind every output

Insights

When the Company’s Own Words Outweighed the Ownership Chart

When the Company’s Own Words Outweighed the Ownership Chart

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Bill C-31 Gives the CRA More Power and a Greater Advantage in Tax Disputes

Bill C-31 Gives the CRA More Power and a Greater Advantage in Tax Disputes

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Unwinnable from the Start: A Deemed-Resident Trust's Appeal, Chobham Corporation Ltd. v. HMK

Unwinnable from the Start: A Deemed-Resident Trust's Appeal, Chobham Corporation Ltd. v. HMK

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What a Tax Opinion Answers, and What It Doesn't

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....

Tax Opinion Before Implementation | Supportability, Assumptions, and CRA Reassessment

What a Tax Opinion Supports Before Implementation

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...

CRA Reassessment After a Tax Opinion

CRA Reassessment After a Tax Opinion

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...

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