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ARTICLE · 26 FEBRUARY 2025

CRA In-Audit Conflict: Managing Risk & Taking Control

Counter Tax Litigators LLP
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The data shows that CRA is hunting more tax revenue. CRA audits are not neutral reviews – they are structured to challenge tax positions and extract revenue.

CanadaAccounting and Audit
Peter Aprile
Peter Aprile
James Roberts
James Roberts
Natalie Worsfold
Natalie Worsfold
Jennifer Mak
Jennifer Mak
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Key Takeaways for Leaders

  • A CRA audit is not just a process - it's a conflict, unfolding in real-time. Leaders who treat it as routine compliance fail to recognize the trends, the CRA's approach, and the risks.
  • EY reports that 70% of theleaders report they lack appropriate visibility into their ongoing tax disputes. Recognizing conflict levels early, aligning teams, and responding strategically ensures control and minimizes financial exposure.
  • A structured CRA In-Audit Escalation Framework enables leadership to gain visibility and stay ahead. Our framework aims to help leaders and tax teams respond more effectively to in-audit conflict. It helps them recognize that by Level 2, the audit has already shifted against the business. By Level 4, CRA has framed the dispute, leaving few opportunities to influence the outcome.

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