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

The Post-Reassessment Decision Window in a CRA Dispute

The Post-Reassessment Decision Window in a CRA Dispute

February 11, 2026 - In large-corporation CRA disputes, management must make consequential decisions immediately after reassessment while information remains incomplete and positions unsettled. This does not reflect a...

When a Tax Court Appeal Becomes Cost, Not Opportunity

When a Tax Court Appeal Becomes Cost, Not Opportunity

February 06, 2026 - Key Takeaways The appeal failed because the parties continued after the win path had closed. The hearing created no real opportunity or upside. The case continued without a clear stop-point, turning...

The Early Decision Window in a CRA Dispute

The Early Decision Window in a CRA Dispute

February 06, 2026 - In large-corporation CRA disputes, the period immediately following reassessment is defined by unresolved conditions. Information is incomplete. Interpretations remain unsettled. Exposure cannot yet...

Where an Interest Deduction Dispute Is Effectively Shaped

Where an Interest Deduction Dispute Is Effectively Shaped

February 06, 2026 - Keybrand Foods Inc. v. HMQ, shows how interest-deductibility disputes, and others like them, are shaped after reassessment as the objection record crystallizes the explanation of the business...

Management’s First Explanation in a CRA Dispute

Management’s First Explanation in a CRA Dispute

December 23, 2025 - A CRA dispute begins when CRA issues its reassessment. Management’s first test begins when it explains it to directors, shareholders, lenders, investors, or partners. The structure varies. 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...

Explore more insights >