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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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How Courts Decide When a Transaction Can Be Read Two Ways

Strategy that Shapes the Outcome

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

How Courts Decide When a Transaction Can Be Read Two Ways

Nov 24, 2025 4:46:13 PM - Key Takeaways Penn Ventilator v. HMQ shows how disputes evolve when a transaction supports two viable case theories: one tied to the structure, the other to the business’s economic behaviour. Courts...

Background Pattern 2 with Strategy Insights text - Shaping CRA Audit Outcomes Before Reassessment, trusted representation for complex, high-stakes tax disputes.

Shaping CRA Audit Outcomes Before Reassessment

Feb 21, 2025 6:49:16 PM - This article is part of CFO Tax Dispute Insights, Counter Tax Litigators LLP’s executive series delivering strategic guidance to private businesses and CFOs on navigating high-stakes CRA disputes, rea...

Background Pattern 2 with Caselaw Insights text - Hidden Tax Risks in Corporate Life Insurance, strategic tax dispute navigation with deep legal expertise by Counter Tax Litigators LLP.

Hidden Tax Risks in Corporate Life Insurance

Feb 11, 2024 7:30:00 AM - Executive Summary A recent ruling by the Federal Court of Appeal in Gestion M.-A. Roy Inc. v Canada, 2024 CAF 16, underscores a growing risk in corporate tax planning: life insurance premiums paid by ...

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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