Nov 4, 2024 8:45:00 AM - 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 e...

Our latest thinking on tax dispute issues and strategies for private company leaders, high-net-worth individuals, and their advisors.
Nov 4, 2024 8:45:00 AM - 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...
Nov 4, 2024 8:45:00 AM - 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 e...
Oct 17, 2024 6:45:00 AM - Counter Tax Litigators LLP is excited to announce the updated Practical Insight on Penalties under the Income Tax Act (2024), authored by Peter Aprile, James Roberts, and Jennifer Mak, and published b...
Oct 4, 2024 8:15:00 AM - The Federal Court of Canada’s decision in Onex Corporation v. Canada (Attorney General)[1] highlights a meaningful development for taxpayers challenging the Agency’s discretionary decisions. The FC’s ...
Jun 14, 2024 6:45:00 AM - Cryptocurrencies have redefined wealth creation but also bring unprecedented challenges for tax planning and compliance. As cryptocurrency values soar and governments worldwide heighten scrutiny, Cana...
Jan 21, 2024 3:34:00 PM - 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 commitment...
Nov 16, 2023 7:43:29 PM - 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).
Sep 7, 2023 5:53:00 PM - 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 carryove...
Aug 15, 2023 7:07:00 PM - If a CRA or DoJ lawyer recently contacted you regarding a tax dispute you're not directly involved in, following the completion of an audit, you might feel uncertain about how to proceed. You may have...
Jul 5, 2023 6:59:00 PM - 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 ...
Jul 3, 2023 5:17:40 PM - Counter Tax Litigators LLP is pleased to announce the release of the updated Practical Insight into Judicial Review under the Income Tax Act (2022), authored by Peter Aprile and James Roberts, and pub...
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