Operating Context

CRA disputes require early position control and disciplined sequencing.

Structural
Constraint

When a CRA dispute escalates, options narrow and positions harden.

Point of
Intervention

Counter LLP enters at the audit, objection, and litigation stages where exposure becomes material and executive oversight applies.

Judgment Disciplines

Position Viability

The position must withstand Appeals, litigation, and downstream governance review.

Procedural Lock-In

Premature commitments constrain later outcomes.

Governance Visibility

Executives and boards require decision-ready outputs.

Experienced tax lawyer with expertise in tax law, dispute navigation, and elite persuasion skills.

System Architecture

A single litigation system governs all matters and constrains individual discretion.

Confident tax lawyer who uses advanced systems to enhance capabilities and secure superior outcomes.
Framework Graphic 1 – representing Counter Tax Litigators' integrated approach to client service, combining advanced systems and deep legal expertise to resolve high-stakes tax disputes.

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