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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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CRA Reassessments Behave Like Capital Events

Strategy that Shapes the Outcome

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CRA Reassessments Behave Like Capital Events

Nov 24, 2025 10:15:24 AM - Key Takeaways CRA’s incentive design produces earlier, larger, and more persistent reassessments. The Large Corporation Rules convert those assertions into temporary capital constraints. For...

Counter Sphere 1 Image, with “CRA Reassessments Behave Like Capital Events” title text, Counter Tax Litigators LLP: strategic leadership in complex CRA disputes.

CRA Reassessments Behave Like Capital Events

Nov 24, 2025 10:15:24 AM - Key Takeaways CRA’s incentive design produces earlier, larger, and more persistent reassessments. The Large Corporation Rules convert those assertions into temporary capital constraints. For executive...

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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