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Our latest thinking on tax dispute issues and strategies for mid-market business leaders, affluent families, and their advisors.

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Foreign Tax Interest Denied, Tax Court Loss Contained — Bank of Montreal v. HMK

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Foreign Tax Interest Denied, Tax Court Loss Contained — Bank of Montreal v. HMK

Sep 22, 2025 8:45:00 AM - Key Takeaways The Tax Court confirmed that foreign tax interest is not deductible — BMO lost on the law. The result was predictable, but BMO's strategy maximized potential upside while containing the...

The Three Critical Inflection Points in CRA Challenges

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...

Controlling CRA Exposure: Pre-Audit to Audit (Overview)

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 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.

The Objection Stage as CRA’s Self-Review

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.

DOJ & CRA Post-Audit Inquiries: A Guide for Non-Parties

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...

Tax partner from Price Waterhouse Coopers commending Peter Aprile and the Counter Tax Litigators team for their hands-on, focused, and diligent approach to tax law.

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

Senior VP client with an accounting and finance background praising Counter Tax Litigators for their expertise, dedication, and businesslike approach to tax dispute litigation.

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

Accountant representing Fuller Landau LLP praising Counter Tax Litigators for superior communication in resolving client tax disputes.

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

Retired CEO client recommending Peter Aprile and the Counter Tax Litigators team for their competence, honesty, and exceptional handling of legal matters.

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

Successful business leader praising Counter Tax Litigators’ team for their professional, efficient representation, leading to a highly satisfactory decision.

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

Business leader praising the Counter Tax Litigators team for going above and beyond in handling a significant tax dispute.

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

Recognition

For nearly 20 years, our leadership in Canadian tax controversy and litigation has earned consistent recognition for expertise, results, and client trust.

Framework Graphic 1 – representing Counter Tax Litigators' integrated approach to client service, combining advanced systems and deep legal expertise to resolve high-stakes tax disputes.

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