Featured Insights

Management’s First Conversation with the Board in a CRA Dispute

Dec 23, 2025 12:53:35 PM - A CRA dispute does not begin at the board table. It begins earlier, when a proposal letter signals that CRA will issue a notice of reassessment and management recognizes that a board explanation will...

Strategy and Outcomes

Analysis circulated periodically.

Counter Sphere 1 Image, with “The Three Critical Inflection Points in CRA Challenges” title text, Counter Tax Litigators LLP: judgment-driven advocacy in high-stakes tax litigation.

Sep 7, 2025 12:31:46 PM - 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 representing...

Subtle abstract background used in Counter Tax Litigators LLP’s Managing CRA Dispute Risk series, accompanying an insight on CRA offshore exposure and early visibility.

May 15, 2025 7:15:00 AM - The CRA no longer relies on blunt audit tactics to detect offshore non-compliance. It operates a layered system; data-driven, globally integrated, and increasingly predictive. Most taxpayers facing of...

Mar 5, 2025 3:27:19 PM - This article is part of Counter Tax Litigators LLP’s "Private Enterprise Tax Risk & Dispute Series," delivering strategic guidance to finance leaders monitoring and navigating high-stakes tax risks, c...

Background Pattern 2 with Caselaw Insights text - Offshore Asset Risk: Azmayesh-Fard v HMK & Strategic Dispute Planning, expert tax dispute services for mature businesses and wealthy families by Counter Tax Litigators LLP.

Feb 13, 2025 8:15:00 AM - Key Takeaways from Azmayesh-Fard v HMK Enforcement is accelerating. CRA’s access to global financial data has fundamentally changed how offshore holdings are detected. Risk is dynamic. Proactive tax d...

Background Pattern 2 with Tax Strategy Insights text - The Objection Stage as CRA’s Self-Review, protect the value you’ve created with premier tax litigators, Counter Tax Litigators LLP.

Oct 24, 2024 8:15:00 AM - This article was prepared by Counter LLP’s Tax Controversy and Litigation practice, with contributions from Peter Aprile, Senior Counsel; James Roberts, Partner; and Jennifer Mak, Associate. The CRA o...

Strategy Insights - DOJ & CRA Post-Audit Inquiries: A Guide for Non-Parties, clarity and superior tax dispute results provided by Counter Tax Litigators LLP.

Aug 15, 2023 7:07:00 PM - Key Takeaways for Non-Parties Declining involvement is the default, standard, and strategic approach. DoJ and CRA inquiries post-audit do not create a legal obligation to respond. Written communicatio...

Caselaw Insights - When Insurance Premiums Lead to Unwanted Shareholder Benefits, expert tax dispute services for mature businesses and wealthy families by Counter Tax Litigators LLP.

Jun 8, 2023 1:23:30 PM - 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 s...

Tax Dispute Insights - Counter Partners' Update Chapter on Corporate Residence Disputes & Strategies, strategic tax dispute navigation with deep legal expertise by Counter Tax Litigators LLP.

May 23, 2023 11:56:52 AM - We’re delighted to announce our newly updated chapter on Corporate Residence & Tax Disputes in Canada (2023), published by Thomson Reuters, is now available.

Background Pattern 2 with Strategy Insights text - Preparing for Discovery in a Tax Dispute, deep expertise and strategic dispute resolution from Counter Tax Litigators LLP.

Feb 11, 2023 3:19:46 PM - You increase the odds of getting the desired outcome when you give effective discovery answers. Here are some tips to help you.