Executive Summary Tax litigation sits at the intersection of mandates distributed across the Canada Revenue Agency, the Department of Justice, the Tax Court of Canada (the Court), and the Department o...
Executive Summary Canada’s tax-dispute and litigation system operates without coordinated architecture or design leadership. No institution is responsible for aligning conduct, accountability, and pro...
[Executive Summary Canada’s tax-dispute system lacks a stable way to examine how procedural changes shape the system as a whole. Each institution sees only part of the landscape. As a result, reforms ...
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 question...
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. Meetin...
Chambers Canada 2026 recognized Peter Aprile and Counter Tax Litigators LLP for excellence in tax litigation, reflecting a record of credible outcomes in CRA disputes.
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 ...
Executive Abstract A CRA dispute unfolds across multiple institutions with different incentives and objectives. After a reassessment is issued, control over the advice and guidance shapes how the disp...
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 representing...
This article appeared in Thomson Reuters’ Tax Disputes & Resolution Centre, alongside leading resources on managing complex tax controversies.