Framework Graphic 1 – representing Counter Tax Litigators' commitment to improving the tax dispute system and community through impactful initiatives and expert contributions.
Framework Graphic 1 – representing Counter Tax Litigators' commitment to improving the tax dispute system and community through impactful initiatives and expert contributions. Blue

Impact Initiatives

We commit our time and expertise to improve the tax dispute system and community.

A COO and CEO discuss operations inside a mid-market manufacturing facility, reinforcing Counter Tax Litigators’ role in driving systemic tax dispute reforms that protect businesses from unfair CRA and DoJ litigation practices.
Experienced woman tax professional, representing the Count Her In initiative connecting women excelling in the tax community.

Recognition

For nearly 20 years, our leadership in Canadian tax controversy and litigation has earned consistent recognition for expertise, results, and client trust.

Insights

CRA Offshore Exposure: How Risk Builds Before the Reassessment

Offshore Asset Exposure: How the CRA Builds Its Case Before You Know You're in One

May 15, 2025 - The CRA no longer relies on blunt audit tactics to detect offshore non-compliance. It operates a layered system; data-driven, globally integrated, and increasingly predictive. Most taxpayers facing...

Controlling CRA Exposure: Pre-Audit to Audit (Overview)

Controlling CRA Exposure: Pre-Audit to Audit (Overview)

March 05, 2025 - This article is part of Counter Tax Litigators LLP’s "Private Enterprise Tax Risk & Dispute Series," delivering strategic guidance to finance leaders monitoring and navigating high-stakes tax risks,...

The CRA’s Tax Earned by Audit Metric & March 31st Target: A System for Tax Disputes

The CRA’s Tax Earned by Audit Metric & March 31st Target: A System for Tax Disputes

February 28, 2025 - Key Takeaways Data shows a surge in improper CRA reassessments leading up to March 31, driven by TEBA targets and March 31 fiscal year-end pressures. CRA audits, driven by TEBA targets,...

Shaping CRA Audit Outcomes Before Reassessment

Shaping CRA Audit Outcomes Before Reassessment

February 21, 2025 - This article is part of CFO Tax Dispute Insights, Counter Tax Litigators LLP’s executive series delivering strategic guidance to private businesses and CFOs on navigating high-stakes CRA disputes,...

The Evolving Landscape of Supply Classification

The Evolving Landscape of Supply Classification

February 14, 2025 - Key Challenge: Clarifying GST/HST Supply Classification Integrated Transactions: Tax professionals should proactively evaluate whether elements of a purchase are truly independent or part of a...

Offshore Asset & T1135 Risk: Azmayesh-Fard v HMK & Strategic Dispute Planning

Offshore Asset & T1135 Risk: Azmayesh-Fard v HMK & Strategic Dispute Planning

February 13, 2025 - Key Takeaways from Azmayesh-Fard v HMK Enforcement is accelerating. CRA’s access to global financial data has fundamentally changed how offshore holdings are detected. Risk is dynamic. Proactive...

Framework Graphic 1 – representing Counter Tax Litigators' integrated approach to client service, combining advanced systems and deep legal expertise to resolve high-stakes tax disputes.

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