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

A Tax Court case reveals how settlement agreements can become unstable when institutions attempt to modify terms after acceptance. The dispute centered on whether additional implementation terms could be added...

Understanding the real turning points in CRA challenges — and how to use them to strengthen position and improve results...

After a reassessment, management begins making decisions before the full facts and positions are clear.

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...

In large-corporation CRA disputes, the period immediately following reassessment is defined by unresolved conditions. Information is incomplete. Interpretations remain unsettled.

A tax opinion may confirm that a filing position is defensible, but does it address how that structure will perform when the Canada Revenue Agency challenges it? This analysis examines the gap between implementation support and dispute readiness, exploring what remains unanswered after the opinion is delivered and why multiple participants may assess different aspects without evaluating the structure outside the implementation frame.

A CRA Notice of Reassessment sets out the Agency's position and the amount now assessed. The immediate question is what happens next.

Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability.

Private businesses - those with annual revenues typically ranging from $10 million to $250 million - form the backbone of Canada's private sector, contributing significantly to economic growth.

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.

Mid-market companies - those with annual revenues typically ranging from $10 million to $250 million - form the backbone of Canada's private sector...

Penn Ventilator v. HMQ shows how disputes evolve when a transaction supports two viable case theories: one tied to the structure, the other to the business's economic behaviour.

The Canada Revenue Agency (CRA) operates within an incentive structure that influences audit behaviour in ways that businesses must consider.

Leadership responses at the audit stage now directly shape the trajectory of tax disputes and how boards evaluate the CFO's judgement.

In Glencore Canada Corporation v. His Majesty the King ("Glencore FCA"), the Federal Court of Appeal examined and ultimately rejected Glencore's contention regarding the tax treatment of commitment fees and non-completion fees.

The Federal Court of Appeal's ("FCA") decision in Enns v. Canada[1] clarifies how "spouse" is defined for purposes of paragraph 160(1)(a) of the Income Tax Act ("ITA").

The Canada Revenue Agency may examine your TFSA transactions and argue that you were engaged in the business of trading securities within your TFSA.

Accountants that unthinkingly send the Agency tax appeal invoices improperly reveal solicitor-client communications and more.

Canada's tax treaties are the third factor that may impact corporate tax residence.