The Canada Revenue Agency’s Tax Earned by Audit (TEBA) metric tracks the gross value of tax assessed through audit activity. Although TEBA does not determine ultimate liability, it influences internal...
CRA audits establish the first durable version of an interpretive dispute. Before reassessment issues, audit interactions fix transaction characterizations, embed interpretive assumptions, and narrow ...
Canadian Lawyer has again recognized Counter Tax Litigators LLP as one of Canada’s top tax law boutiques in its 2025 – 2026 rankings, reflecting the firm's trust in handling the country’s most complex...
Key Challenge: Clarifying GST/HST Supply Classification Integrated Transactions: Tax professionals should proactively evaluate whether elements of a purchase are truly independent or part of a single ...
Key Takeaways from Azmayesh-Fard v HMK Enforcement is accelerating. CRA’s access to global financial data has fundamentally changed how offshore holdings are detected. Risk is dynamic. Proactive tax d...
The Federal Court of Appeal’s (“FCA”) decision in Enns v. Canada[1] clarifies how “spouse” is defined for purposes of paragraph 160(1)(a) of the Income Tax Act (“ITA”). This decision carries significa...
When CRA issues a Notice of Reassessment (NoR), taxpayers who contest it face a structural choice: remain in CRA’s self-adjudication stage at objection, or transition to the Tax Court’s independent ov...
This article was prepared by Counter LLP’s Tax Controversy and Litigation practice, with contributions from Peter Aprile, Senior Counsel; James Roberts, Partner; and Jennifer Mak, Associate. The CRA o...
Counter Tax Litigators LLP has contributed an updated chapter on Income Tax Penalties in Canada, authored by Peter Aprile, James Roberts, and Jennifer Mak, and published by Thomson Reuters in its Tax ...
Coopers Park (2024 TCC 122) shows CRA intensifying its push to access accountant communications in tax disputes. The risk rises when legal and accounting teams blend, and it remains invisible until th...