CRA Reassessments Behave Like Capital Events

Key Takeaways

• CRA's incentive design produces earlier, larger, and more persistent reassessments.
• The Large Corporation Rules convert those assertions into temporary capital constraints.
• For executives and boards, a reassessment behaves like a capital markets event that unfolds inside the company.

How CRA's Audit Design Shapes the Dispute Arena

CRA's audit model no longer affects only the audit stage. It influences the form, scale, and timing of the disputes that follow.

Under the Tax Earned by Audit (TEBA) metric, audit teams receive credit for the gross value of tax they assess. TEBA captures what is asserted, not what ultimately endures. This separates two ideas that once moved together: issuance and validity.