Counter Tax Litigators LLP

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

What A Tax Opinion Answers, And What It Doesn't

What A Tax Opinion Supports Before Implementation

CRA Reassessment After A Tax Opinion

CRA Settlement After A Reassessment: When Resolution Becomes Unstable

Dispute Record Risk At CRA Reassessment

Notice Of Objection Failed To Define The Dispute

Notice Of Objection Window | What Carries Forward

CRA Dispute Record Formation | Decisions Made Before Clarity

CRA Reassessment | What Happens Next

Canada · Corporate/Commercial Law

Leveraged Growth And The CRA Reassessment Cycle

The Post-Reassessment Decision Window In A CRA Dispute

24 February 2026

Canada · Strategy

The Early Decision Window In A CRA Dispute

12 February 2026

When A Tax Court Appeal Becomes Cost, Not Opportunity

12 February 2026

Where An Interest Deduction Dispute Is Effectively Shaped

12 February 2026

Canada · Litigation, Mediation & Arbitration

Management's First Conversation With The Board In A CRA Dispute

30 December 2025

When Institutional Continuity Becomes Management Exposure

18 December 2025

Canada · Strategy

System Advantage And Late-Shifting Positions In Transfer Pricing Disputes

18 December 2025

How Courts Decide When A Transaction Can Be Read Two Ways

01 December 2025

Canada · Corporate/Commercial Law

Loss Consolidation Under GAAR: When Interpretation And Judgement Decide The Outcome

28 November 2025