Framework Graphic 1 – illustrating Counter Tax Litigators' deep tax law expertise, enhanced by its advanced systems and holistic strategies for superior outcomes in high-stakes tax disputes.
Framework Graphic 1 – illustrating Counter Tax Litigators' deep tax law expertise, enhanced by its advanced systems and holistic strategies for superior outcomes in high-stakes tax disputes.

A Comprehensive Analysis of Income Tax Penalties

Update to the leading guide on penalties under the Income Tax Act, published by Counter Tax Litigators LLP x Thomson Reuters.

Counter Tax Litigators LLP expertise in tax controversy and litigation, representing successful companies and high-net-worth individuals in CRA disputes
Tax partner from Price Waterhouse Coopers commending Peter Aprile and the Counter Tax Litigators team for their hands-on, focused, and diligent approach to tax law.

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

Senior VP client with an accounting and finance background praising Counter Tax Litigators for their expertise, dedication, and businesslike approach to tax dispute litigation.

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

Accountant representing Fuller Landau LLP praising Counter Tax Litigators for superior communication in resolving client tax disputes.

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

Retired CEO client recommending Peter Aprile and the Counter Tax Litigators team for their competence, honesty, and exceptional handling of legal matters.

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

Successful business leader praising Counter Tax Litigators’ team for their professional, efficient representation, leading to a highly satisfactory decision.

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

Business leader praising the Counter Tax Litigators team for going above and beyond in handling a significant tax dispute.

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

Recognition

Our law firm and tax lawyers regularly receive
recognition as leaders in tax controversy and litigation.

Insights

A Comprehensive Analysis of Income Tax Penalties in Canada

A Comprehensive Analysis of Income Tax Penalties in Canada

July 17, 2024 - Counter Tax Litigators LLP is excited to announce the updated Practical Insight on Penalties under the Income Tax Act (2024), authored by Peter Aprile, James Roberts, and Jennifer Mak, and published...

Avoiding and Navigating Tax Disputes in the Mining Sector

Avoiding and Navigating Tax Disputes in the Mining Sector

January 21, 2024 - In Glencore Canada Corporation v. His Majesty the King[1](“Glencore FCA”), the Federal Court of Appeal examined and ultimately rejected Glencore’s contention regarding the tax treatment of...

Tax Disputes & ITC Claim Protection When Suppliers Fall Short

Tax Disputes & ITC Claim Protection When Suppliers Fall Short

November 17, 2023 - The Tax Court of Canada’s recent ruling in Fiera Foods Company v. HMK1 has significant implications for businesses claiming Input Tax Credits (ITCs) under the Excise Tax Act (ETA).

Deans Knight Will Have a Serious Impact on Tax Planning & Tax Disputes

Deans Knight Will Have a Serious Impact on Tax Planning & Tax Disputes

September 07, 2023 -

Mining in the Tax Court: Glencore’s Challenge to Exclude Fees from Taxable Income

Mining in the Tax Court: Glencore’s Challenge to Exclude Fees from Taxable Income

July 05, 2023 - Key Points in Glencore The case involves an appeal against a reassessment under the Income Tax Act, where the Minister of National Revenue assessed as income certain fees Falconbridge received due...

When Insurance Premiums Lead to Unwanted Shareholder Benefits

When Insurance Premiums Lead to Unwanted Shareholder Benefits

June 08, 2023 - Management M.-A. Roy Inc. v. HMK (“Gestion Roy”) centers around whether an Opco’s decision to pay insurance premiums, with two Holdcos as the policy owners, gives rise to a shareholder benefit under...

Framework Graphic 1 – representing Counter Tax Litigators' integrated approach to client service, combining advanced systems and deep legal expertise to resolve high-stakes tax disputes.

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