May 23, 2023

Counter Partners' Update Chapter on Corporate Residence Disputes & Strategies

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We’re delighted to announce our newly updated chapter on Corporate Residence & Tax Disputes in Canada (2023), published by Thomson Reuters, is now available.

The legal landscape, case law, and Canada Revenue Agency’s positions shift continually. Expecting evolution and uncertainty is part and parcel of this dynamic field. This comprehensive guide sheds light on the evolving world of corporate tax residence disputes.

I understand the issues CEOs and CFOs face when navigating an emerging or existing corporate residence dispute. We’re always searching for ways to give these leaders the clarity they need.

I hope this chapter will increase our clients’ and their advisors’ knowledge. I hope this work adds value.

– Peter Aprile, Partner, Tax Litigation

In the updated chapter, you will find:

Exploration of how COVID-19 changes the landscape and weighting.
Insights about where the central management and control test might head next.
Helpful strategies and common pitfalls that taxpayers encounter in corporate residence disputes.

We invite you to read this updated chapter and learn more about corporate residence and tax disputes in Canada.

Insights

Stay updated on overturning CRA penalties with Counter Tax Litigators LLP's leading guide on penalties under the Income Tax Act.

Tax Dispute Insights - Avoiding and Navigating Tax Disputes in the Mining Sector, superior tax dispute representation for high-stakes cases by Counter Tax Litigators LLP.

Navigating tax disputes in mining: Learn from Glencore's case to optimize M&A & tax dispute outcomes. Explore insights from our tax lawyers.

Caselaw Insights - Tax Disputes & ITC Claim Protection When Suppliers Fall Short, expert tax dispute services for mature businesses and wealthy families by Counter Tax Litigators LLP.

The Tax Court of Canada’s recent ruling in Fiera Foods Company v. HMK has significant implications for businesses claiming Input Tax Credits.

Background Pattern 2 with Strategy Insights text - CRA's Objection Process: Full Engagement vs. Strategic Disengagement, unique expertise in overturning CRA reassessments by Counter Tax Litigators LLP.

Discover the benefits of fully engaging or strategically disengaging from CRA's internal objection process. Explore expert insights for favourable results.

Caselaw Insights - Deans Knight Will Have a Serious Impact on Tax Planning & Tax Disputes, expert tax dispute services for mature businesses and wealthy families by Counter Tax Litigators LLP

Explore the impact of Deans Knight on tax in Canada. Navigate the GAAR & post-Deans Knight era. This article offers an expert view of Canada's tax system.

Background Pattern 2 with Strategy Insights text - A Non-Party’s Guide to Responding Safely to Post-Audit Tax Dispute Inquiries, protect the value you’ve created with premier tax litigators, Counter Tax Litigators LLP.

Non-party to a tax dispute? Protect your interests when the CRA or DoJ contacts you about another taxpayer. Get expert tips on responding safely.

Explore more insights >

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

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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Counter Partners' Update Chapter on Corporate Residence Disputes & Strategies

Insights

A Comprehensive Analysis of Income Tax Penalties in Canada

Avoiding and Navigating Tax Disputes in the Mining Sector

Tax Disputes & ITC Claim Protection When Suppliers Fall Short

CRA's Objection Process: Full Engagement vs. Strategic Disengagement

Deans Knight Will Have a Serious Impact on Tax Planning & Tax Disputes

A Non-Party’s Guide to Responding Safely to Post-Audit Tax Dispute Inquiries

How can we help you?

Recognition

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