Counter Tax Litigators Launches ‘1% for Tax Accountability’

Counter Tax Litigators LLP has launched 1% for Tax Accountability, a first-of-its-kind initiative dedicated to strengthening Canada’s tax dispute system and ensuring fairer, more predictable tax litigation outcomes for mid-market businesses. 1% for Tax Accountability partners with the firm's past clients, mid-market business leaders, and other stakeholders to drive high-level tax dispute reforms that hold Canadian tax authorities accountable, reduce risk for businesses, and create a more balanced tax controversy and litigation arena.

Through 1% for Tax Accountability, Counter Tax LLP dedicates 1% of all legal fees to targeted, high-impact projects that challenge unfair tax authority conduct and drive improvements across the entire tax dispute resolution process - from legislation to administrative procedures to enforcement mechanisms.

“In addition to representing our mid-market business clients in tax controversy and litigation matters - we’re driving systemic change beyond individual disputes, ensuring the entire tax dispute system operates with greater predictability and accountability,” said Peter Aprile, Senior Counsel and leader of the initiative. “Businesses rely on a tax dispute system that is fair, predictable, and accountable. But right now, the CRA and DoJ operate without real oversight, and businesses are forced to bear the financial and strategic consequences of their unchecked decisions. 1% for Tax Accountability allows us to challenge these structural failures at every level - legislation, dispute resolution rules, tax litigation procedures, and enforcement safeguards.”

What This Means for Canadian Businesses

The tax dispute system is stacked against businesses - slow, costly, and often tilted in favour of tax authorities. 1% for Tax Accountability directly benefits mid-market businesses by:

• Driving legislative and regulatory reforms to update the Income Tax Act, Tax Court of Canada Rules, and related legislation to enhance accountability and procedural fairness in tax disputes.
• Expanding enforcement mechanisms to hold the CRA and DoJ accountable for procedural abuses, unreasonable delays, and unfair litigation tactics.
• Strengthening oversight frameworks by proposing reforms to expand the authority of the Taxpayers’ Ombudsperson to ensure meaningful consequences for tax authority misconduct in disputes.
• Challenging harmful CRA and DoJ internal dispute resolution policies that create unnecessary financial and operational burdens on businesses.
• Developing precedent-setting litigation strategies that force systemic change in how tax authorities conduct audits, objections, and tax litigation.

“This initiative is about high-level, business-first tax dispute integrity,” said Natalie Worsfold, Managing Partner at Counter Tax LLP. “Government agencies should not be able to avoid accountability at the expense of business leaders facing tax disputes that can have significant financial and operational consequences. We're taking the lead in shaping a tax litigation system that works for businesses - not just accepting or reacting to systemic failures.”

How Counter Tax Litigators is Leading Tax Dispute System Reform

Through 1% for Tax Accountability, Counter Tax LLP actively leads and contributes to major industry-wide tax dispute and litigation reforms in key areas, including:

• Legislative and procedural modernization – Advocating for amendments to the Income Tax Act, Tax Court of Canada Rules, and other dispute resolution frameworks to increase transparency, ensure proportionality, reduce unnecessary litigation costs, and introduce clearer tax appeal and resolution timelines.
• Accountability and enforcement reform – Working to expand the Taxpayers’ Ombudsperson’s authority to ensure the CRA and DoJ face real consequences for implicit bad-faith conduct and other CRA and DoJ failures in tax disputes.
• Policy and administrative oversight improvements – Analyzing and challenging internal DoJ and CRA litigation policies that allow for unjustified delays, selective disclosure of evidence, and disproportionate dispute resolution tactics.
• Targeted litigation to force systemic change – Pursuing strategic cases that challenge tax authority overreach, set legal precedents in tax litigation, and drive structural improvements in the tax dispute process.

A Business-Focussed Initiative, Independent from Government and Special Interests

While Counter Tax Litigators actively contributes to leading tax reform organizations such as:

• The Tax Court Bench and Bar Committee
• The Ontario Bar Association (OBA) Taxation Law Section
• The Canadian Tax Foundation (CTF)

“Our work with organizations like the OBA and CTF allows us to contribute to broad industry discussions on tax reform. However, our 1% Initiative gives us the autonomy to directly address the specific tax accountability issues that impact its mid-market and high-net-worth clients navigating tax disputes,” said Aprile. 

“Many organizations contribute to tax reform, but businesses need a more targeted, strategic approach to address systemic tax dispute challenges. Canadian business leaders need someone else to step up and provide a more structured, proactive approach to tax dispute reform that directly protects their interests. 1% for Tax Accountability drives targeted, high-impact reforms that reduce unnecessary risk, improve outcomes, and ensure mid-market businesses operate within a fairer, more predictable tax system.”

Shaping the Future of Tax Dispute Resolution

The 1% for Tax Accountability Initiative reflects a broader global shift toward proactive tax governance and regulatory fairness. Leading businesses recognize that passive compliance and reactive dispute management no longer suffice. Instead, a strategic, systemic approach is essential to mitigate risk and shape tax litigation outcomes.

We see practices and patterns - in Canada and other jurisdictions - that undermine the integrity of the tax dispute system and taxpayer rights,” said Aprile. “Audits and disputes should not unfold on an uneven playing field. We aim to promote fairness and accountability before businesses even enter the tax dispute process. The 1% for Tax Accountability Initiative protects mid-market businesses - and all taxpayers - not just when they face a tax dispute, but well before an audit or legal challenge where they might face the CRA and DoJ on an uneven playing field.”

About Counter Tax Litigators LLP

Counter Tax Litigators LLP leads in tax controversy and litigation, specializing in resolving complex, high-stakes disputes. Counter LLP partners with mid-market businesses and affluent families to protect the economic value they’ve created.

With deep tax expertise and advanced systems, Counter LLP aims to deliver superior results at every stage and arena, from negotiations to judge-mediated settlements and formal hearings. The outcomes Counter LLP has achieved for its clients have earned the firm consistent recognition among Canada’s top tax litigation firms, including accolades from International Tax Review, The Legal 500, and Canadian Lawyer.

Media Contact

Peter Aprile 
Senior Counsel, Tax Controversy & Litigation
Counter Tax Litigators LLP
paprile@countertax.ca