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    • Featured
      • Mutual Fund Trust Disputes: When Form Without Execution Collapses
      • Surplus Cash and the Active Asset Test: Lessons from Ehresman
      • Strategic Deferral of Departure Tax: Security, Liquidity, and Control
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      • Mutual Fund Trust Disputes: When Form Without Execution Collapses
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      • Strategic Deferral of Departure Tax: Security, Liquidity, and Control
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    • Featured
      • Mutual Fund Trust Disputes: When Form Without Execution Collapses
      • Surplus Cash and the Active Asset Test: Lessons from Ehresman
      • Strategic Deferral of Departure Tax: Security, Liquidity, and Control
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Featured Insights

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

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Mutual Fund Trust Disputes: When Form Without Execution Collapses

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Receive quarterly insights to inform tax risk and shape outcomes at every stage.

Mutual Fund Trust Disputes: When Form Without Execution Collapses

Aug 21, 2025 8:15:00 AM - 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...

Background Pattern 2 with Caselaw Insights text - The Evolving Landscape of Supply Classification, reaffirming that only tax statutes—not invoices or regulations—define separate supplies.

The Evolving Landscape of Supply Classification

Feb 14, 2025 9:15:00 AM - Key Challenge: Clarifying GST/HST Supply Classification Integrated Transactions: Tax professionals should proactively evaluate whether elements of a purchase are truly independent or part of a single ...

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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.

2025 Legal500 Elite Boutique Award (Badge)
ITR Finalist Practice Leader of Year Peter Aprile 2024 (Badge)
Recognition from Canadian Lawyer for Counter Tax Litigators as a Top Tax Law Boutique for 2023-24
2025 Legal500 Leading Firm Client Satisfaction Award (Badge)
Excellence Award from Canadian Law Awards recognizing Peter Aprile as Litigator of the Year.
Award from Legal 500 Canada recognizing Counter Tax Litigators as an Elite Tax Boutique for 2024.
Martindale-Hubbell AV Preeminent badge for Counter Tax Litigators, awarded for highest overall client rating.
ITR Tax Innovator Finalist 2024 Award (Badge)
Recognition from Canadian Lawyer for Counter Tax Litigators as a Top Tax Law Boutique for 2021-22.
Lexpert 2022 Rising Star award for Natalie Worsfold, recognizing her excellence in tax litigation.
Martindale-Hubbell AV Preeminent badge for Counter Tax Litigators, peer-rated for highest level of professional excellence.
FT Innovative Lawyers award recognizing Counter Tax Litigators for advanced systems enhancing tax lawyers' capabilities and outcomes.
Precedent 2022 Innovation Award honoring Counter Tax Litigators for innovation in tax litigation reports.
Fastcase 50 award recognizing Counter Tax Litigators for thought leadership and innovation in tax litigation.
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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