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.


Speak to Peter & James about this article



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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.

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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.

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Counter’s representation on our behalf was well informed, professional and efficient, which ultimately resulted in a highly satisfactory decision in all aspects.

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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.

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