For additional analysis, see our Insights.
.jpg?width=120&name=Counter%20Tax%20Litigators%20Logo%20Stacked%20(MidnightBlue%20on%20White).jpg)
The Canada Revenue Agency (“CRA”) is launching a new project named the Related Parties Initiative (“RPI”) aimed at wealthy individuals and related entities. The CRA intends to initiate the RPI audits sending a 22 page questionnaire to taxpayers that the CRA has selected for audit.
We recommend that taxpayers who have failed to report taxable income retain legal counsel and initiate a voluntary disclosure as soon as possible. In addition, we recommend that taxpayers who receive the RPI questionnaire retain legal counsel to assist them in providing the CRA with appropriate answers to proper CRA requests for information. Last, we recommend that taxpayers dispute any improper CRA reassessment.
For additional analysis, see our Insights.
We recommend that taxpayers who have failed to report taxable income retain legal counsel and initiate a voluntary disclosure as soon as possible.
The Federal Court of Appeal in Potash Corp. confirms that under ITA s.165(1.11), a large corporation’s Notice of Objection fixes the outer boundary of a tax dispute. Issues not described at that stage cannot be raised in litigation later.
We want to focus on winning your tax dispute. We created these online FAQs to add clarity to our billing and payment process now (and avoid distraction later).
CRA audits and tax disputes are evolving. Private businesses face rising tax risks. Learn how to manage CRA interactions and reduce risk strategically.
Chambers Canada 2026 recognized Counter LLP and Peter Aprile for excellence in tax litigation, judgment-led strategies, and results delivered in high-stakes CRA disputes.
Publication update announcing Counter Tax Litigators LLP’s 2023 Thomson Reuters chapter on corporate residence disputes and strategies in Canadian tax litigation.