Featured Insights

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

Dec 23, 2025 12:53:35 PM - A CRA dispute does not begin at the board table. It begins earlier, when a proposal letter signals that CRA will issue a notice of reassessment and management recognizes that a board explanation will...

Strategy and Outcomes

Analysis circulated periodically.

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.

Dec 12, 2025 4:42:50 PM - Key Takeaways The Tax Court’s mandate allows the DOJ and CRA to introduce new alternative theories late in litigation, which can increase cost, delay the litigation timeline, and introduce litigation ...

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.

Nov 24, 2025 4:46:13 PM - Key Takeaways Penn Ventilator v. HMQ shows how disputes evolve when a transaction supports two viable case theories: one tied to the structure, the other to the business’s economic behaviour. Courts r...

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

Nov 24, 2025 1:27:15 PM - Key Takeaways The mechanics worked, but the Court focused on whether the reorganization produced a real economic loss or merely a paper one. That distinction shaped the GAAR outcome. The decisive batt...

Counter Sphere 1 Image, with “When Institutional Continuity Becomes Management Exposure” title text, Counter Tax Litigators LLP: judgment-driven advocacy in high-stakes tax litigation.

Sep 19, 2025 9:30:00 AM - Executive Abstract A CRA dispute unfolds across multiple institutions with different incentives and objectives. After a reassessment is issued, control over the advice and guidance shapes how the disp...

Tax Dispute Insights - A Comprehensive Analysis of Income Tax Penalties in Canada, strategic tax dispute navigation with deep legal expertise by Counter Tax Litigators LLP.

Oct 17, 2024 6:45:00 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...

Background Pattern 2 with Caselaw Insights text - Federal Court Sets Higher Bar for CRA: A Win for Taxpayers in Disputes, unique expertise in overturning CRA decisions by Counter Tax Litigators LLP.

Oct 4, 2024 8:15:00 AM - The Federal Court of Canada’s decision in Onex Corporation v. Canada (Attorney General)[1] highlights a meaningful development for taxpayers challenging the Agency’s discretionary decisions. The FC’s ...

Background Pattern 2 with Tax Dispute Insights text -Supreme Court of Canada Clarifies Tax Disputes Arenas, strategic tax dispute navigation with deep legal expertise by Counter Tax Litigators LLP.

Jul 24, 2024 10:15:00 AM - Recent Supreme Court of Canada (SCC) rulings provide critical guidance on tax dispute jurisdiction, shaping how tax reassessments and ministerial decisions should be challenged.

Tax Dispute Insights - Avoiding and Navigating Tax Disputes in the Mining Sector, superior tax dispute representation for high-stakes cases by Counter Tax Litigators LLP.

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...

Caselaw Insights - Tax Disputes & ITC Claim Protection When Suppliers Fall Short, expert tax dispute services for mature businesses and wealthy families by Counter Tax Litigators LLP.

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).

Caselaw Insights - Deans Knight Will Have a Serious Impact on Tax Planning & Tax Disputes, expert tax dispute services for mature businesses and wealthy families by Counter Tax Litigators LLP

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...