Skip to content

There are no suggestions because the search field is empty.

Capabilities
Insights
Case Studies
About
Contact

Capabilities
Insights
Case Studies
About
Contact

Capabilities
Insights
Case Studies
About
Contact

Abstract network sphere of connected points and lines, symbolizing clarity, judgment, and control in complex tax disputes.

hero_bg

Foundations

Authoritative reference chapters on Canadian tax disputes.

<< Back to Insights

Background Pattern 2 Midnight Blue background with White Text - CRA Audits and Disputes: A New Test of Control and Judgement, unique expertise in overturning CRA reassessments by Counter Tax Litigators LLP.

CRA Audits and Disputes: A New Test of Control and Judgement

Key Points CRA can now compel sworn questioning. The Income Tax Act authorizes auditors to require oral testimony under oath during audits, bringing executives directly into the record. Early question...

Counter Sphere 1 Image, with “The Standards That Enable Settlement in Tax Disputes” title text, Counter Tax Litigators LLP: strategic leadership in complex CRA disputes.

The Standards That Enable Settlement in Tax Disputes

This article appeared in Thomson Reuters’ Tax Disputes & Resolution Centre, alongside leading resources on managing complex tax controversies.

Background Pattern 2 with Startegy Insights text - Strategic Deferral of Departure Tax: Security, Liquidity, and Control, strategic tax dispute navigation with deep legal expertise by Counter Tax Litigators LLP.

Departure Tax Deferral

Key Insights at a Glance Deferral as strategy: Departure tax can be deferred without interest when acceptable security is posted, preserving liquidity during transition. Forms of security: CRA accepts...

Audit-Stage Record Formation Under CRA Enforcement Models

CRA audits build the first version of the dispute. Before a notice of reassessment issues, the audit process fixes factual characterizations, embeds interpretive assumptions, and narrows the range of ...

Background Pattern 2 with Strategy Insights text - The CRA’s TEBA Metric & March 31st Target: A System for Tax Disputes, Tax Dispute Trends are provided by Counter Tax Litigators LLP.

Tax Earned by Audit (TEBA) and Fiscal Year-End Dynamics

The Canada Revenue Agency’s Tax Earned by Audit (TEBA) metric tracks the gross value of tax assessed through audit activity. Although TEBA does not determine ultimate liability, it influences internal...

CRA Audit Escalation in Interpretive Tax Disputes

CRA Audit Escalation in Interpretive Tax Disputes

CRA audits establish the first durable version of an interpretive dispute. Before reassessment issues, audit interactions fix transaction characterizations, embed interpretive assumptions, and narrow ...

Background Pattern 2 with Tax Strategy Insights text - The Objection Stage as CRA’s Self-Review, protect the value you’ve created with premier tax litigators, Counter Tax Litigators LLP.

CRA Objections in Interpretive Tax Disputes

This article was prepared by Counter LLP’s Tax Controversy and Litigation practice, with contributions from Peter Aprile, Senior Counsel; James Roberts, Partner; and Jennifer Mak, Associate. The CRA o...

Corporations Without Residence: Corporate Tax Residency, superior tax dispute representation for high-stakes cases by Counter Tax Litigators LLP.

Corporations Without Residence: Corporate Tax Residency

* Thomson Reuters regards the authors as individuals with expertise in tax and litigation. Thomson Reuters has published five Practical Insight chapters on different tax controversy topics, which Coun...

Tax Dispute Insights - The Standard of Review in Judicial Review Proceedings, strategic tax dispute navigation with deep legal expertise by Counter Tax Litigators LLP.

Standard of Review in Federal Judicial Review

* Thomson Reuters regards the authors as individuals with expertise in tax and litigation. Thomson Reuters has published five Practical Insight chapters on different tax controversy topics, which Coun...

Corporate Tax Residency Tips & Traps, advanced systems and strategic dispute resolution from Counter Tax Litigators LLP.

Corporate Tax Residency and Central Management

*Thompson Reuters considers the authors “leading tax experts and litigators”. This content first appeared in TR’s, Practical Insights in May 2020.*

The Concepts of Central Management & Control: Corporate Tax Residency, clarity and superior tax dispute results provided by Counter Tax Litigators LLP.

Central Management and Control

*Thompson Reuters considers the authors “leading tax experts and litigators”. This content first appeared in TR’s, Practical Insights in May 2020.*

Capabilities
- Capabilities Overview
Insights
About

Contact

Subscribe to receive CRA reassessment and dispute insights

© Counter Tax Litigators 2026

Chambers Global
Chambers Canada
International Tax Review

Contact
Terms of Use
Privacy Policy
Disclaimer