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ARTICLE · 06 NOVEMBER 2025

CRA Audits And Disputes: A New Test Of Control And Judgement

Counter Tax Litigators LLP
Counter Tax Litigators LLP
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Counter Tax Litigators LLP

Counter Tax Litigators LLP

Counter is a Toronto-based law firm that specializes in resolving tax controversies across Canada....

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Leadership responses at the audit stage now directly shape the trajectory of tax disputes and how boards evaluate the CFO's judgement.

CanadaAccounting and Audit
Peter Aprile
Peter Aprile
Natalie Worsfold
Natalie Worsfold
James Roberts
James Roberts
Jennifer Mak
Jennifer Mak
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Leadership responses at the audit stage now directly shape the trajectory of tax disputes and how boards evaluate the CFO's judgement.

Key Points

  • CRA can now compel sworn questioning. The Income Tax Act authorizes auditors to require oral testimony under oath during audits, bringing executives directly into the record.
  • Early questioning shapes credibility and outcomes. Sworn answers influence how the CRA, auditors, and lenders interpret executive discipline, control, and the factual narrative.
  • For CFOs, risk now centres on judgment. Audit scrutiny has shifted from compliance review to the optics and consequences of control—testing how leadership handles visibility before the board is informed.

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