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ARTICLE · 15 MAY 2026

CRA Reassessment After A Tax Opinion

Counter Tax Litigators LLP
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A company receives a CRA reassessment after obtaining tax opinions that supported its original filing positions and transaction structures. The reassessment introduces new challenges as CRA reframes transactions...

CanadaTax
Counter Tax Litigators
Counter Tax Litigators
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A company receives a CRA reassessment after prior planning work and tax opinions supported the transactions or filing positions. The company believes the core risk has already been addressed. The original filing position was reviewed. The company obtained the opinion. The company filed accordingly.

The CRA reassessment starts a different problem.

Most tax opinions support a narrower objective. They assess whether the company can support a filing position, reporting treatment, or interpretation on a defined factual record and accepted assumptions.

The CRA reassessment changes the terrain and the requirements.

CRA now tests whether the facts, assumptions, and transaction structure continue to hold under challenge. CRA reframes the transactions, advances new characterizations, and carries the dispute into the objection stage and beyond.

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