The fine line that separates winning and losing a tax dispute

The fine line that separates winning and losing a tax dispute

July 2020 Update: We've added a few resources that should be helpful when making your decision, including our proprietary CounterMeasure software & our law firm comparison tool.

We are entrepreneurs and tax lawyers and, therefore, we think we know a little bit about building a business. We are very aware that building a successful business is all-consuming. It is not easy to lead – and sometimes drag – a business to success. Also, we know that a tax dispute is one of the biggest threats to a business’ continued success and that it is imperative that entrepreneurs and SMEs win the right result.

If the Canada Revenue Agency has issued an improper reassessment, entrepreneurs face two choices: fight smart or crumble. Here’s what you need to know if you are going to fight.

Tax disputes are replete with details and small moments and, if you mishandle these opportunities, they are gone forever.

A fine line separates winning and losing. The margin of error is small. Winning a tax dispute takes place one word, one paragraph, one piece of evidence, one carefully crafted argument, and one decision at a time. In some cases, the key to success lies in strategic omissions. In every case, success is in the details and small moments. An unsupported fact, a logical fallacy, the wrong argument, or a reckless interaction can lead to a loss. Tax disputes are replete with details and small moments and, if you mishandle these opportunities, they are gone forever.

We work to optimize every word, paragraph, and argument to provide our clients with the best opportunity to win. We exhaustively review, edit, and question every detail, case, and strategic decision. Additionally, we've created a proprietary software to ensure that all of this work will lead to the best possible outcomes for our clients. We collect, review, and leverage every tax dispute data point. We do this because we know that the sum of these details and decisions make the difference between winning and losing. 

We are very proud of the calibre of our work and reputation. However, we understand that a lot of lawyers look the same and, if you are not do not have any experience with tax dispute and tax litigation lawyers, you may find it difficult to assess and choose the best option. At times, separating the contenders and pretenders is difficult. We understand. Everyone says they’re the best. The low-rent lawyers try to persuade potential clients that all tax lawyers are equal and that any tax lawyer can deliver an optimal result. We know that’s not true. At the other end, BigLaw lawyers try to persuade potential clients that BigLaw lawyers deliver the highest quality and best results. We know that’s not true too. In fact, we believe that the bigger that BigLaw gets, the more likely that it has lost its passion, the more likely it has lost its drive to produce something great, and the more likely that it lost its connection to the entrepreneurs and SMEs that it seeks to serve.

We believe that the bigger that BigLaw gets, the more likely that it has lost its passion...

We are not low-rent lawyers. We are not BigLaw. We are a Small Giant. We are a tax law firm that has chosen to focus on quality work and results. We won’t tell you that we are the best. Instead, we suggest that you look at the evidence and make your judgment. We invite you to analyze the quality of our work, the quality of our results, and the quality of our writing and thought in the articles we publish. We recommend that you speak to former clients, along with other lawyers and accountants in the legal and tax community. Also, we suggest that you review the quality of the awards that we have won and, more importantly, the reasons why we won and how that impacts our client work.

We encourage you to use our law firm comparison tool to weigh our firm against every other option. We love competition. And, at the risk of sounding boastful, we are confident that the evidence and your analysis will lead you to conclude that our firm has what it takes to push past the fine line that separates winning and losing.

Good luck.


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

David Cuddy in a blue button up shirt standing in a park

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

Laura Couvrette smiling in a plaid top standing with arms folded

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?


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