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.
A company receives a CRA reassessment after prior planning work and tax opinions supported the transactions or filing positions. The company believes the core risk has already been addressed. The...
Key Takeaways The decisive failure in Zhang v. HMK was not mechanical. The CRA lost control of its ability to change the outcome after it accepted a settlement proposal. The taxpayer preserved...
By the time the CRA issues the reassessment, the record is already taking shape. During the objection, the CRA will reinforce its interpretation of the facts and how they apply. That view appears in...
Key Takeaways The reassessment shows the financial exposure. What moves forward depends on how the taxpayer frames the dispute in the Notice of Objection. In this case, the taxpayer’s Notice of...
A CRA Notice of Reassessment has been issued. The deadline to file a Notice of Objection is now active. Management is deciding how to respond. At this stage, management can still shape the response....
After a reassessment, management begins making decisions before the full facts and positions are clear. They set an initial view of exposure. They identify the assumptions that support it. They...
