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.

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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.

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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

When Institutional Continuity Becomes Management Exposure

When Institutional Continuity Becomes Management Exposure

December 15, 2025 - 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...

System Advantage and Late-Shifting Positions in Transfer Pricing Disputes

System Advantage and Late-Shifting Positions in Transfer Pricing Disputes

December 12, 2025 - 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...

Loss Consolidation Under GAAR: When Interpretation and Judgement Decide the Outcome

Loss Consolidation Under GAAR: When Interpretation and Judgement Decide the Outcome

November 25, 2025 - Key Takeaways Loss consolidation transactions attract CRA scrutiny even when they align with Parliament’s design. The mechanical structure rarely drives the dispute – the interpretive record does.

How Courts Decide When a Transaction Can Be Read Two Ways

How Courts Decide When a Transaction Can Be Read Two Ways

November 24, 2025 - 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. ...

When Corporate Losses Require More Than Mechanics

When Corporate Losses Require More Than Mechanics

November 24, 2025 - 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...

Control and Economic Reality in Cross-Border Dividend Disputes

Control and Economic Reality in Cross-Border Dividend Disputes

November 24, 2025 - Key Takeaways Inconsistent cross-border descriptions created tension between the structure’s design and its economic reality. Risk and benefit flowed to different entities across jurisdictions,...

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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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