CRA challenges are often described procedurally, but the decisive moments are structural shifts: when CRA sets out its likely position, when it formalizes that position, and when independent oversight becomes available. Each inflection point alters probabilities and options.
Tax disputes are often treated as binary. In practice, principled floors and defensible standards enable earlier, credible settlements.
Grenon v. Canada shows how mutual fund trust status can fail when execution doesn’t match form. Courts scrutinize RRSP structures that promise tax benefits without real distribution.
Ehresman shows how surplus cash can cost LCGE access when reserves and records are missing. Courts often treat silence as evidence. Outcomes turn on how those gaps are addressed.
Departure tax deferral allows taxpayers to post security. The taxpayer's deferral choices significantly impact liquidity, valuation disputes, and control in cross-border transitions.
MEGLobal Canada ULC shows how forum and timing defined a transfer pricing dispute. The case illustrates how jurisdictional limits can leave strong positions unheard and statute-barred.
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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
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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
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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
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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
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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
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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
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