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.

1% for Tax Accountability

We dedicate 1% of all legal fees to driving systemic reforms that hold the CRA and DoJ accountable and improve tax controversy and litigation outcomes for businesses.

Learn more >
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.

Count Her In: Women in Tax Network

This initiative connects and promotes women excelling in the tax community with over 8 years of practice.

Learn more >
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

Mutual Fund Trust Disputes: When Form Without Execution Collapses

Mutual Fund Trust Disputes: When Form Without Execution Collapses

August 21, 2025 - Key Takeaways Benefit without cost invites scrutiny: Courts scrutinize tax structures that offer benefit without tradeoff, and when they find this gap, they side with the CRA and uphold the...

Surplus Cash and the Active Asset Test: Lessons from Ehresman

Surplus Cash and the Active Asset Test: Lessons from Ehresman

August 14, 2025 - Key Takeaways No inference of intent: Courts rejected the claim that surplus cash was earmarked for decommissioning in the absence of contemporaneous reserves, allocations, or disclosures. ...

Strategic Deferral of Departure Tax: Security, Liquidity, and Control

Strategic Deferral of Departure Tax: Security, Liquidity, and Control

August 11, 2025 - 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...

Transfer Pricing Disputes: How Forum Choice Alters Outcomes

Transfer Pricing Disputes: How Forum Choice Alters Outcomes

June 30, 2025 - Key Takeaways Forum defines outcomes: The taxpayer’s appeal was quashed without the merits ever being heard because the chosen forum lacked jurisdiction. Procedure equals substance: Courts...

Framing Gaps in SR&ED Disputes Shift Control to CRA

Framing Gaps in SR&ED Disputes Shift Control to CRA

June 05, 2025 - Key Takeaways Framing gap: The Tax Court accepted CRA’s framing because Vortex’s reply lacked engineering support and legal positioning. In other disputes, when claims were framed with qualified...

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...

Explore more insights >
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.

How can we help you?

Get in touch