October 17, 2024

Publication Update: Income Tax Penalties in Canada

Updated chapter published in Thomson Reuters’ Tax Disputes & Resolution Centre (2024)

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Counter Tax Litigators LLP has contributed an updated chapter on Income Tax Penalties in Canada, authored by Peter Aprile, James Roberts, and Jennifer Mak, and published by Thomson Reuters in its Tax Disputes & Resolution Centre.

Penalties under the Income Tax Act remain a significant source of dispute between taxpayers and the Canada Revenue Agency, often turning on complex statutory criteria, evidentiary standards, and questions of taxpayer conduct. The updated chapter addresses the legal framework governing civil penalties in Canada and the issues that most frequently arise in penalty assessments and challenges.

The publication reflects developments in the law as of 2024 and draws on practical experience in advising on and litigating penalty disputes.

What the chapter covers

The updated chapter examines:

The statutory framework for civil penalties under the Income Tax Act
Non-discretionary penalties, gross negligence penalties, and third-party penalties
Legal tests, evidentiary thresholds, and available defences
Recent legislative and jurisprudential developments affecting penalty assessments

Access

The chapter is available through Thomson Reuters.

For readers seeking Counter’s current, maintained reference on this topic, see:

Foundations: Income Tax Penalties in Canadian Tax Disputes

Insights

Counter Tax Litigators LLP is recognized in ITR World Tax’s 2026 Tax Controversy rankings. The listing reflects an external review of the firm’s approach to resolving complex Canadian tax disputes.

Chambers Canada Ranking Badge, Peter Aprile Recognized Among Canada’s Top Tax Litigators, demonstrating tax litigation expertise and track record of credible outcomes

Chambers Canada 2026 recognized Counter LLP and Peter Aprile for excellence in tax litigation, judgment-led strategies, and results delivered in high-stakes CRA disputes.

Canada Law Awards Image with Natalie Worsfold, Excellence Awardee, Female Trailblazer of the Year text, recognition for the outcomes he delivered for clients in complex and high-stakes Canadian tax disputes.

The Canadian Law Awards named Counter Tax Litigators LLP’s Natalie Worsfold a finalist for Female Trailblazer of the Year, recognizing her leadership and judgment in complex tax disputes.

Canadian Lawyer Top Tax Boutique Award Badge , Counter Tax Litigators Recognized Among Canada’s Top Tax Law Boutiques, demonstrating Counter Tax Litigators’ tax litigation expertise and excellence.

Counter Tax Litigators LLP ranks among Canada’s top tax boutiques again, recognized for expertise, strategic insight, and success in high-stakes disputes.

Publication Update: Income Tax Penalties in Canada, strategic tax dispute navigation with deep legal expertise by Counter Tax Litigators LLP.

Publication update announcing Counter Tax Litigators LLP’s 2024 Thomson Reuters chapter on income tax penalties under the Income Tax Act.

Peter Aprile from Counter Tax Litigators LLP Named Tax Disputes & Litigation Practice Leader of the Year

Peter Aprile recognized as a finalist for Tax Disputes & Litigation Practice Leader of the Year, highlighting Counter Tax Litigators' excellence in complex tax dispute resolution.

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Publication Update: Income Tax Penalties in Canada

What the chapter covers

Access

Insights

Counter LLP Included in ITR World Tax’s 2026 Tax Controversy Rankings

Counter Tax Litigators LLP and Peter Aprile Recognized in Chambers Canada 2026 for Tax Litigation

Natalie Worsfold Named Finalist for Female Trailblazer of the Year for Leadership in Complex Tax Disputes

Counter Tax Litigators Recognized Among Canada’s Top Tax Law Boutiques