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July 17, 2024

A Comprehensive Analysis of Income Tax Penalties in Canada

Update to the leading guide on penalties under the Income Tax Act, published by Counter Tax Litigators LLP x Thomson Reuters.
By Communications Team
A Comprehensive Analysis of Income Tax Penalties in Canada
A Comprehensive Analysis of Income Tax Penalties in Canada
3:07

Counter Tax Litigators LLP is excited to announce the updated Practical Insight on Penalties under the Income Tax Act (2024), authored by Peter Aprile, James Roberts, and Jennifer Mak, and published by Thomson Reuters in its Tax Disputes & Resolution Centre, is now available.

The Canada Revenue Agency's legislation, case rulings, and stances are constantly changing. Navigating these shifts and uncertainties is crucial in this evolving field. This comprehensive guide offers insights into the intricate realm of penalties.

A Comprehensive Analysis of Income Tax Penalties in Canada

Counter Tax Litigators LLP invites readers to explore this updated Practical Insight, now embedded in the announcement, and gain a deeper understanding of penalties under the Income Tax Act.

Overturning Penalties and Providing Clarity

"Overturning penalties under the Income Tax Act requires experience and a deep understanding of the legislation and case law," said Peter Aprile, Senior Counsel, Tax Controversy and Litigation at Counter Tax Litigators LLP.

"We continually strive to enhance our knowledge and capabilities to effectively challenge the CRA's imposition of penalties. Working on this update further enhanced our expertise, and we hope it will prove valuable for our clients and their advisors."

In the Updated Practical Insight, readers will find:

  • Comprehensive Overview of Civil Penalties Under the Income Tax Act: Including non-discretionary, gross-negligence, and third-party penalties.
  • In-depth Analysis: Detailed examination of the legal criteria and defences available to taxpayers.
  • Practical Strategies: Effective approaches to address and mitigate penalties.
  • Current Insights: How recent legislative and caselaw impacts penalty assessments and defences. 

Expertise in Overturning CRA Assessments and Reassessments

Counter Tax Litigators LLP excels in helping clients navigate and overturn CRA assessments and reassessments that impose penalties. The firm’s deep expertise in this area ensures that clients receive the most effective representation, resulting in superior outcomes.


About Counter Tax Litigators LLP

Counter Tax Litigators LLP ranks as one of Canada’s top tax controversy and litigation law firms. The firm represents mature and financially successful companies in CRA tax disputes. Its competitive advantage becomes most evident in the appeal stage, excelling in negotiations, judge-mediated settlement conferences, and, when necessary, formal hearings. The firm's blend of deep tax law expertise, strategic navigation, ISO-like standards, and advanced systems ensures superior outcomes.

For more information about Counter Tax Litigators LLP, please visit www.countertax.ca.

 


Media Contact:

Peter Aprile
Senior Counsel, Tax Controversy & Litigation 
paprile@countertax.ca

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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.

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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

Accountant representing Fuller Landau LLP praising Counter Tax Litigators for superior communication in resolving client tax disputes.

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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

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.

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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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