Governance & Standards

Every file at Counter LLP exists inside a governing system that no one at the firm has the authority to set aside. 

 
The standards that control how a dispute is analyzed, how strategy is set, how execution proceeds, and how the matter is reported to boards, audit committees, and lenders — are encoded in the firm's governing architecture. They were built specifically for tax dispute work. They apply from first engagement through Tax Court. They do not change as the dispute escalates.

No lawyer at Counter LLP has unilateral authority to waive them. Divergence requires a formal process — a defined basis, visible to the firm, subject to challenge and resolution before the matter advances. There is no informal version of how work gets done here.

  • Every position requires a defined analytical basis before it is advanced.

  • Every material decision is recorded before the matter proceeds.

  • Every assumption carried forward is identified and attributed.

The exposure forecasts, resolution path analyses, and decision records a CFO receives are produced by a required analytical process. That process must be completed before the outputs exist. The record of a file — every material decision, every assumption carried forward, every position change — is built as the dispute develops. It does not need to be assembled when the board asks.

This extends to how Counter LLP operates in every arena. Conduct at negotiation, at discovery, before the Tax Court — each governed by encoded standards that define what is required and what is not permitted. The file is controlled in the room as precisely as it is controlled on paper.

 

The work is governed. The record is governed. The standard does not move.

 

 

Insights

Leveraged Growth and the CRA Reassessment Cycle

Leveraged Growth and the CRA Reassessment Cycle

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

The Reassessment Decision Window in a CRA Dispute

The Reassessment Decision Window in a CRA Dispute

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...

Management’s First Explanation in a CRA Dispute

Management’s First Explanation in a CRA Dispute

A CRA dispute begins when CRA issues its reassessment. Management’s first test begins when it explains it to directors, shareholders, lenders, investors, or partners. The structure varies. The...

CRA Reassessments Behave Like Capital Events

CRA Reassessments Behave Like Capital Events

Key Takeaways CRA’s incentive design produces earlier, larger, and more persistent reassessments. The Large Corporation Rules convert those assertions into temporary capital constraints. For...

When Institutional Continuity Becomes Management Exposure

When Institutional Continuity Becomes Management Exposure

Executive Abstract 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...

The Three Critical Inflection Points in CRA Challenges

The Three Critical Inflection Points in CRA Challenges

Peter Aprile, Senior Counsel at Counter LLP, describes three inflection points that define how CRA challenges develop and are resolved. The framework reflects insights drawn from years of...