We resolve high-stakes CRA tax disputes for private business enterprises and affluent families who recognize that success hinges on decisive early strategy.
Strategic leaders engage us before risks escalate, positions harden, and disputes fully form, preserving control, protecting long-term value, and reinforcing defensibility against CRA challenges.
What Accountants Say
Peter Aprile is a very hands on and practical tax lawyer who is very focused and diligent. He is a pleasure to work with.
- Susan Farina, Tax Partner, Price Waterhouse Coopers
What Clients Say
I’m a Senior VP with an accounting and finance background. I’ve worked with lawyers and large law firms. I was referred to Counter to fix a tax dispute. It is very rare to encounter lawyers that combine expertise, dedication, and a businesslike approach to litigation. I have no hesitation in recommending Counter.
- David Cuddy, Senior Vice-President, Finance & Business Operations, CFL
What Accountants Say
Counter Tax Litigators has worked with Fuller Landau to resolve several of our clients’ tax disputes. Counter delivers superior communication.
- Laura Couvrette, CPA, CA, Fuller Landau LLP
What Clients Say
I spent a good part of my career dealing with attorneys on innumerable matters, and found Peter to be extremely competent, open-minded and exceptionally honest. I would not hesitate to use Peter again, and highly recommend the team at Counter Tax Litigators.
- Mark Ram, Retired CEO
What Clients Say
Counter’s representation on our behalf was well informed, professional and efficient, which ultimately resulted in a highly satisfactory decision in all aspects.
- Klaus W. Reif, President, Reif Estate Winery
What Clients Say
I was amazed with the results. They went above and beyond, and I would recommend Counter to any person or business with a significant tax dispute.
- Brian Grott, Northland Screen Corp
Key Considerations for Choosing the Most Effective Process
For nearly 20 years, our leadership in Canadian tax controversy and litigation has earned consistent recognition for expertise, results, and client trust.
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March 05, 2025 - This article is part of CFO Tax Dispute Insights, Counter Tax Litigators LLP’s executive series delivering strategic guidance to private businesses and CFOs on navigating high-stakes CRA disputes,...
February 28, 2025 - Key Takeaways Data shows a surge in improper CRA reassessments leading up to March 31, driven by TEBA targets and March 31 fiscal year-end pressures. CRA audits, driven by TEBA targets,...
February 21, 2025 - Key Takeaways for Leaders A CRA audit is not just a process - it's a conflict, unfolding in real-time. Leaders who treat it as routine compliance fail to recognize the trends, the CRA's approach,...
February 14, 2025 - Key Challenge: Clarifying GST/HST Supply Classification Integrated Transactions: Tax professionals should proactively evaluate whether elements of a purchase are truly independent or part of a...
February 13, 2025 - Key Takeaways from Azmayesh-Fard v HMK Enforcement is accelerating. CRA’s access to global financial data has fundamentally changed how offshore holdings are detected. Risk is dynamic. Proactive...
February 06, 2025 - 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”). This decision carries...
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