Jul 17, 2024 8:53:00 AM - 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...
Jul 17, 2024 8:53:00 AM - 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 b...
Jan 21, 2024 3:34:00 PM - In Glencore Canada Corporation v. His Majesty the King[1] (“Glencore FCA”), the Federal Court of Appeal examined and ultimately rejected Glencore’s contention regarding the tax treatment of commitment...
Nov 16, 2023 7:43:29 PM - The Tax Court of Canada’s recent ruling in Fiera Foods Company v. HMK1 has significant implications for businesses claiming Input Tax Credits (ITCs) under the Excise Tax Act (ETA).
Sep 7, 2023 5:53:00 PM - Section 111 of the Income Tax Act (“ITA”) allows taxpayers to carry losses back and forward to offset income in different taxation years. However, subsection 111(5) restricts non-capital loss carryove...
Jul 5, 2023 6:59:00 PM - Key Points in Glencore The case involves an appeal against a reassessment under the Income Tax Act, where the Minister of National Revenue assessed as income certain fees Falconbridge received due to ...
Jun 8, 2023 1:23:30 PM - Management M.-A. Roy Inc. v. HMK (“Gestion Roy”) centers around whether an Opco’s decision to pay insurance premiums, with two Holdcos as the policy owners, gives rise to a shareholder benefit under s...
May 23, 2023 11:56:52 AM - We’re delighted to announce our newly updated chapter on Corporate Residence & Tax Disputes in Canada (2023), published by Thomson Reuters, is now available.
May 8, 2023 1:27:00 PM - Thompson Reuters considers the authors “leading tax experts and litigators”. The authors agreed to grant TR partial rights to this work. This article first appeared in TR’s Tax Dispute and Resolution ...
Mar 15, 2023 5:25:00 PM - Executive Summary Eastmain believed its CEO’s salary qualified as a “Canadian Exploration and Development Overhead Expenses” and deducted the same. Revenu Québec (“RQ”) denied Eastmain’s 2007 to 2010 ...
Feb 21, 2023 6:14:07 PM - *Thompson Reuters considers the authors “leading tax experts and litigators”. The authors agreed to grant TR partial rights to this work. This article first appeared in TR’s Tax Dispute and Resolution...
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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.
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Counter Tax Litigators has worked with Fuller Landau to resolve several of our clients’ tax disputes. Counter delivers superior communication.
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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.
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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.
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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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