April 21, 2017

Rectification, Section 94.1 & Accountant Confidentiality

Canadian Tax Insights S01E01 (April 2017)

0:22

Peter Aprile and Yoni Moussadji kick-off Canadian Tax Insights, Season 1 Episode 1, to provide accountants with actionable takeaways (and some free verifiable CPD).

In particular, Peter and Yoni share tips related to four recent cases on rectification, Tax Court Rule 58, section 94.1 of the Income Tax Act, and accountant confidentiality.

Presenter

Peter Aprile, Counter Tax Lawyers

Peter Aprile is a senior lawyer specializing in tax dispute resolution and litigation. His vision as Counter’s founder and his everyday role at the firm are one and the same: to be an agent of change, uncovering opportunities and developing strategies that achieve more than anyone expected. A creative thinker, Peter studies problems from all different angles to find what others have missed. He’s also convinced that he likes winning more than most people.

Different people describe Peter in different ways. At the CRA and the federal Department of Justice, the word relentless comes up quite a lot. Admittedly, so does the word a**hole – but it’s often said with a certain grudging respect, if not affection. Peter’s clients call him a saint. Well, some of them, anyway. His colleagues describe him as empowering and harddriving, but fair. Peter’s friends call him loyal. His wife describes him as a lot to deal with, but worth it. Peter encourages his young daughter and son to call him “The Big Homie,” though with limited success. His mother describes him with the single word mischievous – before going on to complain that he should call more.

Read Peter’s complete bio →

Insights

Counter Sphere 1 Image, with “Management’s First Conversation with the Board in a CRA Dispute” title text, Counter Tax Litigators LLP: judgment-driven advocacy in high-stakes tax litigation.

The first board conversation in a CRA dispute happens before clarity. This insight explains how early framing shapes control, narrows options, and influences how boards judge management under pressure.

Counter Sphere 1 Image, with “System Advantage and Late-Shifting Positions in Transfer Pricing Disputes ” title text, Counter Tax Litigators LLP: judgment-driven advocacy in high-stakes tax litigation.

Redpath shows how transfer pricing disputes can shift late. Strategic venue choice counters systemic advantage and protects business strategy.

Counter Sphere 1 Image, with “Loss Consolidation Under GAAR: When Interpretation and Judgement Decide the Outcome” title text, Counter Tax Litigators LLP: disciplined litigation for critical tax disputes.

Quebecor v. HMK underscores that CRA challenges to loss consolidation hinge on interpretation over mechanics and on whether the outcome aligns with Parliament’s intent.

Counter Sphere 1 Image, with “How Courts Decide When a Transaction Can Be Read Two Ways” title text, Counter Tax Litigators LLP: judgment-driven advocacy in high-stakes tax litigation.

A clear view into how courts choose between competing case theories in tax disputes, and why the business’s real decision environment often shapes the interpretation and outcome.

Counter Sphere 1 Image, with “When Corporate Losses Require More Than Mechanics” title text, judgment-driven advocacy for CEOs and CFOs managing high-stakes CRA disputes

Wuswig v. HMK confirms that under GAAR, economic substance and credible purpose, not mechanical compliance, determine whether corporate losses will stand.

Counter Sphere 1 Image, with “Control and Economic Reality in Cross-Border Dividend Disputes” title text, Counter Tax Litigators LLP: disciplined litigation for critical tax disputes.

Analysis of the Husky Energy withholding dispute and how courts chose among competing case theories by aligning structure, operations, and cross-border reporting.

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Rectification, Section 94.1 & Accountant Confidentiality

Presenter

Peter Aprile, Counter Tax Lawyers

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Related Insights

Rectification, Section 94.1 & Accountant Confidentiality

Presenter

Peter Aprile, Counter Tax Lawyers

Insights

Management’s First Conversation with the Board in a CRA Dispute

System Advantage and Late-Shifting Positions in Transfer Pricing Disputes

Loss Consolidation Under GAAR: When Interpretation and Judgement Decide the Outcome

How Courts Decide When a Transaction Can Be Read Two Ways

When Corporate Losses Require More Than Mechanics

Control and Economic Reality in Cross-Border Dividend Disputes

Contact

Subscribe

Stay current with our latest insights.