Counter Tax Litigators LLP practices in tax controversy and litigation.
The firm enters once the CRA’s position is fixed and capital is exposed. It does not provide audit planning, compliance services, or routine advisory work.
The work begins when the dispute becomes formal and capital is exposed.
That mandate has remained unchanged.
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2009
The firm was established to act in tax disputes arising from reassessments.
From inception, the mandate was tax controversy and litigation, not planning.
2014–2015
2015-2018
A structured dispute architecture embedded across all significant matters. Strategy moved from individual craft to an institutional system.
2018
2019
Pre-objection filing exposure analysis and position-setting formalized as a governance requirement across the firm.
No objection or pleading proceeds until executive leadership aligns on exposure and strategic position.
2020
Engagement at the CRA Appeals stage was deliberately narrowed following the filing of the Notice of Objection in large corporation disputes.
Strategic effort reallocated toward independent adjudication and structured resolution planning where institutional leverage is materially greater.
Court-supervised mediation embedded as a formal resolution pathway across significant disputes.
Exposure modeling and settlement architecture aligned to leverage cost asymmetry and accelerate disciplined resolution.
2021
Exposure grading and documented executive-level commitments integrated into dispute execution and stakeholder reporting.
2022
Canadian Institute for Tax Controversy Studies launched as a permanent research arm examining the structural pressures within Canada’s tax dispute regime.
2023
Defined institutional criteria governing acceptance of significant capital-sensitive disputes.
2024
Strategic case leadership formally separated from firm management.
2025
Discipline governing strategy, executive accountability, and formation of the formal dispute record codified across the firm.
February 06, 2026 - Key Takeaways The appeal failed because the parties continued after the win path had closed. The hearing created no real opportunity or upside. The case continued without a clear stop-point, turning...
February 06, 2026 - Keybrand Foods Inc. v. HMQ, shows how interest-deductibility disputes, and others like them, are shaped after reassessment as the objection record crystallizes the explanation of the business...
November 25, 2025 - Key Takeaways Loss consolidation transactions attract CRA scrutiny even when they align with Parliament’s design. The mechanical structure rarely drives the dispute – the interpretive record does.
November 24, 2025 - Key Takeaways Inconsistent cross-border descriptions created tension between the structure’s design and its economic reality. Risk and benefit flowed to different entities across jurisdictions,...
November 20, 2025 - Key Takeaways Enhanced costs continue to rise. The Tax Court again imposed enhanced costs on the Crown, reinforcing a pattern: disciplined conduct in the right arena creates financial consequences...
November 03, 2025 - Key Points CRA can now compel sworn questioning. The Income Tax Act authorizes auditors to require oral testimony under oath during audits, bringing executives directly into the record. Early...
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