Introducing CounterMeasure

We’ve developed proprietary software that determines the best course of action to resolve your tax challenge. CounterMeasure evaluates risks and the probabilities of success, constantly updating the most effective and cost-efficient route for moving ahead. You won't find a program like this at any other law firm. Watch the video below and Contact us for more information.

 

 

Insights

The Three Critical Inflection Points in CRA Challenges

The Three Critical Inflection Points in CRA Challenges

September 07, 2025 - Peter Aprile, Senior Counsel at Counter LLP, describes three inflection points that define how CRA challenges develop and are resolved. The framework reflects insights drawn from years of...

The Standards That Enable Settlement in Tax Disputes

The Standards That Enable Settlement in Tax Disputes

September 03, 2025 - The Shared Challenge Counsel on both sides of tax disputes face the same challenge: how to resolve cases in ways that are fair, objective, and justifiable — settlements that withstand internal and...

Mutual Fund Trust Disputes: When Form Without Execution Collapses

Mutual Fund Trust Disputes: When Form Without Execution Collapses

August 21, 2025 - Key Takeaways Benefit without cost invites scrutiny: Courts scrutinize tax structures that offer benefit without tradeoff, and when they find this gap, they side with the CRA and uphold the...

Surplus Cash and the Active Asset Test: Lessons from Ehresman

Surplus Cash and the Active Asset Test: Lessons from Ehresman

August 14, 2025 - Key Takeaways No inference of intent: Courts rejected the claim that surplus cash was earmarked for decommissioning in the absence of contemporaneous reserves, allocations, or disclosures. ...

Strategic Deferral of Departure Tax: Security, Liquidity, and Control

Strategic Deferral of Departure Tax: Security, Liquidity, and Control

August 11, 2025 - Key Insights at a Glance Deferral as strategy: Departure tax can be deferred without interest when acceptable security is posted, preserving liquidity during transition. Forms of security: CRA...

Transfer Pricing Disputes: How Forum Choice Alters Outcomes

Transfer Pricing Disputes: How Forum Choice Alters Outcomes

June 30, 2025 - Key Takeaways Forum defines outcomes: The taxpayer’s appeal was quashed without the merits ever being heard because the chosen forum lacked jurisdiction. Procedure equals substance: Courts...