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In large-corporation CRA disputes, management must make consequential decisions immediately after reassessment while information remains incomplete and positions unsettled.
This does not reflect a failure of diligence. It reflects the normal operating environment at this stage.
In practice, management fixes the trajectory in the first weeks after reassessment.
The large-corporation regime requires early judgment:
- Management defines the current exposure range and risk level.
- Management identifies the assumptions driving that exposure.
- Management decides how the assessed amount will be handled.
- Management designates who will shape the dispute narrative going forward.
- Management settles the explanation it will carry forward to the board, lenders, partners, or the audit committee.
Management will make each of these decisions while uncertainty persists. The regime does not wait for clarity.
Those decisions are embedded in filings, payment choices, and governance communications.
- Payment choices establish the level of exposure management is prepared to carry.
- Draft filings fix the factual and interpretive characterizations the company relies on.
- Early briefings establish the level of escalation management and governance bodies come to expect.
Individually, these decisions appear provisional. Institutionally, they are not. Together, they form the first permanent record. It takes shape and hardens before management or the board treats it as settled.
When the Notice of Objection is filed, that record becomes the reference point and boundary against which later decisions are judged. Management may try to expand or change course, but revision is no longer neutral. Changes require explanation and draw scrutiny, internally and externally.
Structural context
Why decisions made under uncertainty still become the record
Following reassessment, uncertainty is structural. Facts remain incomplete. Interpretive positions are unsettled. Visibility is limited.
Despite this, the regime requires positions to be entered into the formal record through payment decisions, filings, and governance communications.
Management may, in some cases, adjust those positions later. However, permitted adjustments must reconcile with what was recorded earlier. Tax disputes rarely exceed the budget because of the procedure. They exceed budget when positions and explanations shift.
Dispute outcomes are constrained long before resolution. By the time you argue the law, the record has already set the range.
Teams that act early stabilize the record. Teams that delay inherit it.
Under the large-corporation regime, outcomes tend to follow early decisions made under unresolved conditions. At the end of the dispute, attention turns not only to how it was resolved, but to how management set the company's initial course.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
