Executive Summary
Companies that grow through leveraged acquisitions, refinancing strategies, or complex financing structures eventually encounter the same sequence: CRA audit, reassessment, and dispute.
After the CRA has issued its final audit position and the Notice of Reassessment, the dispute has already begun. Management now faces a set of immediate decisions: assess exposure, align advisors and leadership, brief the board, and determine who will control the objection and any later stages.
Those decisions shape the dispute that follows.
These dynamics often arise in leveraged acquisitions and refinancing strategies.
I. Leveraged Growth Changes the Nature of Tax Disputes
Leveraged acquisitions, refinancing strategies, and layered financing structures change the character of CRA disputes.
