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.
We commit our time and expertise to improve the tax dispute system and community.
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.
This initiative connects and promotes women excelling in the tax community with over 8 years of practice.
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...
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...
September 03, 2025 - This article appeared in Thomson Reuters’ Tax Disputes & Resolution Centre, alongside leading resources on managing complex tax controversies. The Shared Challenge Counsel on both sides of tax...
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...
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. ...
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...