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

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

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

November 03, 2025 - 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...

When CRA Scrutiny Shifts from Mechanics to Interpretive Requirements

When CRA Scrutiny Shifts from Mechanics to Interpretive Requirements

October 29, 2025 - Key Takeaways CRA challenges often evolve from mechanical to interpretive tests. The decisive factor is not a structure’s mechanics but whether its interpretive elements hold up under scrutiny. ...

Foreign Tax Interest Denied, Tax Court Loss Contained — Bank of Montreal v. HMK

Foreign Tax Interest Denied, Tax Court Loss Contained — Bank of Montreal v. HMK

September 22, 2025 - Key Takeaways The Tax Court confirmed that foreign tax interest is not deductible — BMO lost on the law. The result was predictable, but BMO's strategy maximized potential upside while containing...

The Three Critical Inflection Points in CRA Challenges

The Three Critical Inflection Points in CRA Challenges

September 07, 2025 - Peter Aprile, Senior Counsel at Counter LLP, describes three inflection points that define how CRA challenges develop and are resolved. The framework reflects insights drawn from years of...

The Standards That Enable Settlement in Tax Disputes

The Standards That Enable Settlement in Tax Disputes

September 03, 2025 - This article appeared in Thomson Reuters’ Tax Disputes & Resolution Centre, alongside leading resources on managing complex tax controversies.

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...

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