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ARTICLE · 30 DECEMBER 2025

Management's First Conversation With The Board In A CRA Dispute

A CRA dispute does not begin at the board table. It begins earlier, when a proposal letter signals that CRA will issue a notice of reassessment and management recognizes that a board explanation will follow.

CanadaTax

Why the initial framing matters before the dispute takes shape

A CRA dispute does not begin at the board table. It begins earlier, when a proposal letter signals that CRA will issue a notice of reassessment and management recognizes that a board explanation will follow.

That recognition immediately compresses decisions. Management must prepare to brief directors, determine who will frame and carry the dispute, and operate within statutory constraints that apply to large corporations, including objection deadlines and collection rules. These pressures arise before judgment has fully formed.

By the time directors hear about the issue, management has already organized it. That organization sets the initial boundaries for how risk, discretion, and control are understood.

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