A CRA Notice of Reassessment has been issued. The deadline to file a Notice of Objection is now active. Management is deciding how to respond.

The data shows that CRA is hunting more tax revenue. CRA audits are not neutral reviews – they are structured to challenge tax positions and extract revenue.

The Tax Court of Canada allowed Mr. Pat Paletta's estate's appeal.

The Tax Court of Canada's recent ruling in Fiera Foods Company v. HMK has significant implications for businesses claiming Input Tax Credits (ITCs) under the Excise Tax Act (ETA).

The general trend is that Canada Revenue Agency is disallowing more input tax credits ("ITCs") for businesses.

When a CRA auditor thinks the CRA can take a bigger share of your capital, other CRA agents and the CRA's lawyers will fight to extract it.

The CRA's first formal position reshapes liquidity, governance rhythm, and the company's control of the dispute.

Canada's tax-dispute and litigation system operates without coordinated architecture or design leadership. No institution is responsible for aligning conduct, accountability, and proportionality, or for maintaining...

The Federal Court of Canada's decision in Onex Corporation v. Canada (Attorney General) highlights a meaningful development...

Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies.

Companies that grow through leveraged acquisitions, refinancing strategies, or complex financing structures eventually encounter the same sequence: CRA audit, reassessment, and dispute.

Tax opinions answer narrower questions than most readers assume, with limits written into assumptions, scope sections, and dates—and others not written anywhere. Understanding what an opinion actually supports, who it protects, and which questions it leaves unanswered becomes critical when companies face CRA reassessment under notice of objection deadlines.

A CRA dispute unfolds across multiple institutions with different incentives and objectives. After a reassessment is issued, control over the advice and guidance shapes how the dispute is framed...

In Brown v. Canada 2022 FCA 200, the Federal Court of Appeal restated the source-of-income test and applied the test to the taxpayer's management services activity.

Section 111 of the Income Tax Act ("ITA") allows taxpayers to carry losses back and forward to offset income in different taxation years.

Counsel on both sides of tax disputes face the same challenge: how to resolve cases in ways that are fair, objective, and justifiable — settlements that withstand internal and external review.