Counter Partners' Update Chapter on Corporate Residence Disputes & Strategies

We’re delighted to announce our newly updated chapter on Corporate Residence & Tax Disputes in Canada (2023), published by Thomson Reuters, is now available.

The legal landscape, case law, and Canada Revenue Agency’s positions shift continually. Expecting evolution and uncertainty is part and parcel of this dynamic field. This comprehensive guide sheds light on the evolving world of corporate tax residence disputes.

I understand the issues CEOs and CFOs face when navigating an emerging or existing corporate residence dispute. We’re always searching for ways  to give these leaders the clarity they need.

I hope this chapter will increase our clients’ and their advisors’ knowledge. I hope this work adds value.

– Peter Aprile, Partner, Tax Litigation


In the updated chapter, you will find:Corporate Residency TR Practical Insight

  • Exploration of how COVID-19 changes the landscape and weighting.
  • Insights about where the central management and control test might head next.
  • Helpful strategies and common pitfalls that taxpayers encounter in corporate residence disputes.


We invite you to read this updated chapter and learn more about corporate residence and tax disputes in Canada.


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