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Impact Initiatives

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

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Insights

A Comprehensive Analysis of Income Tax Penalties in Canada

A Comprehensive Analysis of Income Tax Penalties in Canada

July 17, 2024 - Counter Tax Litigators LLP is excited to announce the updated Practical Insight on Penalties under the Income Tax Act (2024), authored by Peter Aprile, James Roberts, and Jennifer Mak, and published...

Avoiding and Navigating Tax Disputes in the Mining Sector

Avoiding and Navigating Tax Disputes in the Mining Sector

January 21, 2024 - In Glencore Canada Corporation v. His Majesty the King[1](“Glencore FCA”), the Federal Court of Appeal examined and ultimately rejected Glencore’s contention regarding the tax treatment of...

Tax Disputes & ITC Claim Protection When Suppliers Fall Short

Tax Disputes & ITC Claim Protection When Suppliers Fall Short

November 17, 2023 - The Tax Court of Canada’s recent ruling in Fiera Foods Company v. HMK1 has significant implications for businesses claiming Input Tax Credits (ITCs) under the Excise Tax Act (ETA).

Deans Knight Will Have a Serious Impact on Tax Planning & Tax Disputes

Deans Knight Will Have a Serious Impact on Tax Planning & Tax Disputes

September 07, 2023 - Section 111 of the Income Tax Act (“ITA”) allows taxpayers to carry losses back and forward to offset income in different taxation years. However, subsection 111(5) restricts non-capital loss...

Mining in the Tax Court: Glencore’s Challenge to Exclude Fees from Taxable Income

Mining in the Tax Court: Glencore’s Challenge to Exclude Fees from Taxable Income

July 05, 2023 - Key Points in Glencore The case involves an appeal against a reassessment under the Income Tax Act, where the Minister of National Revenue assessed as income certain fees Falconbridge received due...

When Insurance Premiums Lead to Unwanted Shareholder Benefits

When Insurance Premiums Lead to Unwanted Shareholder Benefits

June 08, 2023 - Management M.-A. Roy Inc. v. HMK (“Gestion Roy”) centers around whether an Opco’s decision to pay insurance premiums, with two Holdcos as the policy owners, gives rise to a shareholder benefit under...

Recognition

Our law firm and tax lawyers regularly receive
recognition as leaders in tax controversy and litigation.

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