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Tax Disputes & ITC Claim Protection When Suppliers Fall Short

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Tax Disputes & ITC Claim Protection When Suppliers Fall Short

November 16, 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).

September 28, 2022 - * Thomson Reuters regards the authors as individuals with expertise in tax and litigation. Thomson Reuters has published five Practical Insight chapters on different tax controversy topics, which Coun...

September 1, 2022 - Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...

August 30, 2022 - Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...

August 18, 2022 - * Thomson Reuters regards the authors as individuals with expertise in tax and litigation. Thomson Reuters has published five Practical Insight chapters on different tax controversy topics, which Coun...

August 15, 2022 - Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...

May 24, 2022 - Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...

May 22, 2022 - Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...

April 6, 2022 - Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...

March 29, 2022 - *Thomson Reuters regards the authors as individuals with expertise in tax and litigation. Thomson Reuters has published five Practical Insight chapters on different tax controversy topics, which Count...

February 23, 2022 - Generally speaking, taxpayers can deduct fees and costs paid to prevent a potential assessment or dispute a reassessment under paragraph 60(o)(i) of the Income Tax Act R.S.C. 1985, c. 1 (the “ITA”). W...

February 9, 2022 - I suspect you started your legal career with the same expectations I had. You expected to spend a lot of time drafting countless legal research memoranda. And I imagine you spent way more hours than y...

January 19, 2022 - *Thompson Reuters considers the authors “leading tax experts and litigators”. The authors agreed to grant TR partial rights to this work. This article first appeared in TR’s, Practical Insights in May...

August 24, 2021 - We work with clients who make and uphold the following promises.

August 3, 2021 - We appreciate your decision to select Counter Tax Litigators LLP as your legal counsel. By choosing to work with us, you accept and agree to our client service terms, detailed below for your reference...

July 21, 2021 - We intend to deliver the best possible tax dispute experience and result. Unfortunately, we cannot give you a guarantee. But we can make specific promises and increase the odds of achieving our goal.

July 27, 2018 - A few months ago, Counter asked me to reflect on my recruitment experience and why I chose to spend my 2L summer with them. I wrote “The Environment that Will Grow Tomorrow’s Best Litigators”. I am no...

July 27, 2018 - I might break the internet if I tried to tell you everything that I learned during my year of articling at Counter. No two weeks are the same. I can do a million things or dig into a couple of large t...

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April 16, 2018 - Peter explains the corporate residence tests and outlines the three types of corporate decisions, (i.e., strategic management decisions, effective management decisions, and junior management decisions...

Guest: Peter Aprile

August 15, 2017 - We’re hiring for a 2L summer student, and we really want the right one. We could simply tell you that our firm is great and you should trust us with your career but, instead, we’re going to do this ot...

July 25, 2017 - My first day at Counter Tax Lawyers was like a movie trailer that makes you mark your calendar for the release date: fun, action packed, and exciting. And it didn’t disappoint.

November 22, 2016 - We believe our greatest strength is how we think. We’re constantly sharpening our skills, solving interesting problems and reaching higher. We started applying traditional risk and decision analysis t...

October 4, 2016 - If you’re facing a tax dispute, you want to hire the best possible lawyer. But how are you supposed to evaluate the skills and experience of a particular law firm? How can you gauge the likelihood of ...

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January 22, 2016 - Tax appeals are highly complex and uncertain. It requires tax lawyers to make decisions based on unknown information and uncertain events. It is impossible to guarantee results or eliminate risk.

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September 23, 2015 - Advocate Daily originally published, “CRA may see influx of tips after Ashley Madison hack”, in September 2015. Relationship strife may not be the only fallout from the recent information hack at the ...

July 28, 2015 - Advocate Daily originally published, “Passion, talent not enough to prove business activities”, in July 2015. A recent Tax Court of Canada decision that questioned whether a hockey blog is a business ...

June 3, 2015 - TORONTO, June 3, 2015 – ATX Law, a Toronto-based tax controversy and litigation firm, is rebranding as Counter Tax Lawyers. The new name better reflects the firm’s niche expertise while showcasing the...

April 30, 2015 - In Tax Court of Canada appeals, the pleadings are the most important documents that the parties file. The Appellant (taxpayer) is required to file a Notice of Appeal, and the Respondent Minister of Na...

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March 23, 2015 - When it comes to launching a successful law practice, a healthy financial foundation is essential, as it will allow a lawyer to focus on bringing in new business, Toronto tax litigation lawyer Peter A...

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January 27, 2015 - The Federal Court of Appeal has recently made it clear that the decision in Canada v. Sommerer [2012] FCA 207 is correct and subsection 75(2) of the Income Tax Act does not apply to property sold for ...

November 24, 2014 - A significant costs award and even-handed analysis provided by the Tax Court of Canada in a recent case will serve to remind the government that tax litigation carries financial consequences, Toronto ...

November 19, 2014 - The Tax Court of Canada has ruled the allowable limits provision of the TCC tariff is not definitive and judges have the discretion to exceed amounts set out in it.

October 6, 2014 - A recent Tax Court of Canada decision will hopefully persuade the Minister of National Revenue to reconsider the routine imposition of harsh penalties for failing to report income, Toronto tax litigat...

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October 3, 2014 - In a potentially precedent-setting case, the Tax Court of Canada has determined that the often “harsh” penalties imposed on taxpayers who misreport income in two out of four years cannot be imposed if...

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May 20, 2014 - The Tax Court of Canada in October last year released its reasons for judgment in Brent Kern Family Trust v. Canada [2013] T.C.J. No. 286. The case was the TCC’s first opportunity to review and apply ...

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April 29, 2014 - Advocate Daily initially originally published, "Tax court should go further when awarding costs”, in March 2014. Although a recent Tax Court of Canada decision shows a continued trend towards higher c...

December 9, 2013 - Advocate Daily originally published “New CRA tools may mean more tax haven proceedings” in December 2013. Although the Canada Revenue Agency has reportedly struggled to deal with the number of cases i...

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November 16, 2013 - Eighteen new words have been added to the Taxpayer Bill of Rights, and Canada’s Taxpayers’ Ombudsman Paul Dube is hoping they will convince hundreds and perhaps even thousands more individuals and bus...

February 15, 2013 - In cases heard under the TCC’s general procedure (as opposed to the informal procedure), the winning party may receive more than the amount of taxes in dispute plus interest—that is, the court may awa...

February 10, 2013 - In its first decision on third party penalties, the Tax Court of Canada has curtailed the power of the Canada Revenue Agency; as expected, the CRA has already decided to appeal.

December 14, 2012 - We have experience representing SR&ED claimants at the objection and appeal stages. At times, we have questioned the CRA’s level of service and processes surrounding SR&ED objections. Today, the CRA p...

December 2, 2012 - Prior to 1999, the Minister of National Revenue and Canada Revenue Agency (hereinafter jointly referred to as the “CRA”) had two legislative tools to severely punish taxpayers, advisors, planners, pro...

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September 3, 2012 - We have written several postings related to the proposed changes in the Tax Court Act and Tax Court Rules. To review, the proposed changes seek to increase the Tax Court Informal Procedure Limits (i.e...

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August 20, 2012 - The Canada Revenue Agency Appeals Branch provided our firm with the following statistics related to the number of tax dispute and tax litigation files along with the rates of settlement, withdrawal an...

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July 16, 2012 - In or about 1995, the “detax” or “untax” movement has been moving through Canada. Since that time, detax organizations have been gaining profit holding seminars that spread the detax philosophy. Gener...

June 16, 2012 - Tucked in with the promise of prosperity, job creation, and fiscal restraint in the federal government’s recent budget was another commitment: to move forward with changes aimed at improving caseload ...

January 4, 2012 - Section 227.1 of the Income Tax Act and section 323 of the Excise Tax Act provide that the CRA can assess corporate directors personally for a corporation’s failure to remit payroll deductions and GST...

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November 22, 2011 - In Bozzer v. Her Majesty the Queen (“Bozzer”), Federal Court of Appeal held that the taxpayer relief provisions contained in the Income Tax Act allow the Minister of National Revenue (“Minister”) and ...

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November 12, 2011 - The Minister of Finance, the Minister of Justice and the Attorney General of Canada have invited the public to comment on proposed changes to the Tax Court of Canada’s Rules.

September 19, 2011 - The Financial Post Executive Podcast just posted our interview entitled “The Practical Taxman Cometh”.

August 23, 2011 - The Tax Court’s Bench and Bar Committee and the Canadian Bar Association’s Tax and Charities sections have sponsored a new resolution proposing that the Canadian Bar Association renew its efforts to p...

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August 8, 2011 - The CRA’s Taxpayers’ Ombudsman reported that several taxpayers contacted the Taxpayers’ Ombudsman office complaining the Tax-Free Savings Account (“TFSA”) rules related to withdrawals and over-contrib...

August 3, 2011 - Notices of reassessments issued by the Canada Revenue Agency (CRA) can have serious financial implications for small businesses. In 2009 and 2010, the CRA audited approximately 380,000 small and mediu...

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August 2, 2011 - The Globe and Mail published an informative article on August 2, 2011 explaining the CRA’s new audit program that targets restaurants using software designed to suppress restaurant sales i.e., zapper ...

July 21, 2011 - The Canada Revenue Agency’s Voluntary Disclosure Program (the ‘‘Program’’) encourages taxpayers to voluntarily disclose unreported income. As set out in Information Circular IC00-1R2, a taxpayer who v...

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April 15, 2011 - Yesterday’s Ontario Bar Association Tax Law Section Conference was a great opportunity for our firm to discuss the Canada Revenue Agency’s (“CRA”) new Related Party Initiative (“RPI”), which targets h...

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March 31, 2011 - The Canada Revenue Agency (“CRA”) is launching a new project named the Related Parties Initiative (“RPI”) aimed at wealthy individuals and related entities. The CRA intends to initiate the RPI audits ...

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November 21, 2008 - Stephen Kaegi and his wife, Elise Dallaire, learned the hard way that music, love and taxes don't always mix well. The Ontario couple have spent two years trying to persuade federal tax officials that...

February 7, 2008 - Six years after the bankruptcy of a car dealership, an Ontario tax collector began pressing its ailing former director for unpaid sales taxes.

Susan Farina wearing a dark blue top and dark rimmed circular glasses brightly smiling while sitting at a desk with a pen and paperwork in front of her

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

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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

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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

Mark Ram standing in a office hallway wearing a white button up with dark blue jacket and dark rimmed glasses

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

Klaus W. Reif sitting at a desk, dressed in a blue jacket with a silver wrist watch

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

Brian Grott wearing a white button up with a red tie with white dots, softly smiling and leaning against a desk

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

How can we help you?

Recognition

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

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