ARTICLE · 24 FEBRUARY 2026

The Post-Reassessment Decision Window In A CRA Dispute

Counter Tax Litigators LLP

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In large-corporation CRA disputes, management must make consequential decisions immediately after reassessment...

CanadaStrategy

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In large-corporation CRA disputes, management must make consequential decisions immediately after reassessment while information remains incomplete and positions unsettled.

This does not reflect a failure of diligence. It reflects the normal operating environment at this stage.

In practice, management fixes the trajectory in the first weeks after reassessment.

The large-corporation regime requires early judgment:

Management defines the current exposure range and risk level.
Management identifies the assumptions driving that exposure.
Management decides how the assessed amount will be handled.
Management designates who will shape the dispute narrative going forward.

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