![](https://www.countertax.ca/hs-fs/hubfs/Tax_Dispute_Insights_Pattern_Purple%26Green.jpg?width=499&height=299&name=Tax_Dispute_Insights_Pattern_Purple%26Green.jpg)
In Glencore Canada Corporation v. His Majesty the King[1] (“Glencore FCA”), the Federal Court of Appeal examined and ultimately rejected Glencore’s contention regarding the tax treatment of...
The Financial Post Executive Podcast just posted our interview entitled “The Practical Taxman Cometh”.
In Glencore Canada Corporation v. His Majesty the King[1] (“Glencore FCA”), the Federal Court of Appeal examined and ultimately rejected Glencore’s contention regarding the tax treatment of...
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).
When you receive a Notice of Reassessment (NoR) from the CRA and decide to contest it, one strategic choice significantly influences both the resources you commit and the outcome: selecting the most...
Section 111 of the Income Tax Act (“ITA”) allows taxpayers to carry losses back and forward to offset income in different taxation years. However, subsection 111(5) restricts non-capital loss...
Key Points in Glencore The case involves an appeal against a reassessment under the Income Tax Act, where the Minister of National Revenue assessed as income certain fees Falconbridge received due to...
Management M.-A. Roy Inc. v. HMK (“Gestion Roy”) centers around whether an Opco’s decision to pay insurance premiums, with two Holdcos as the policy owners, gives rise to a shareholder benefit under...
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
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
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
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
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
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
Our law firm and tax lawyers regularly receive
recognition as leaders in tax controversy and litigation.