The Strategic Choice After Reassessment
Comparing the CRA’s self-adjudication stage with independent oversight in appeal
Our People
We bring disciplined judgement to complex disputes and create the conditions for stronger decisions under pressure.
Insights
December 12, 2025 - Key Takeaways The Tax Court’s mandate allows the DOJ and CRA to introduce new alternative theories late in litigation, which can increase cost, delay the litigation timeline, and introduce...
November 25, 2025 - Key Takeaways Loss consolidation transactions attract CRA scrutiny even when they align with Parliament’s design. The mechanical structure rarely drives the dispute – the interpretive record does.
November 24, 2025 - Key Takeaways Penn Ventilator v. HMQ shows how disputes evolve when a transaction supports two viable case theories: one tied to the structure, the other to the business’s economic behaviour. ...
November 24, 2025 - Key Takeaways The mechanics worked, but the Court focused on whether the reorganization produced a real economic loss or merely a paper one. That distinction shaped the GAAR outcome. The decisive...
November 24, 2025 - Key Takeaways Inconsistent cross-border descriptions created tension between the structure’s design and its economic reality. Risk and benefit flowed to different entities across jurisdictions,...
November 24, 2025 - Key Takeaways CRA’s incentive design produces earlier, larger, and more persistent reassessments. The Large Corporation Rules convert those assertions into temporary capital constraints. For...
What Accountants Say
Peter Aprile is a very hands on and practical tax lawyer who is very focused and diligent. He is a pleasure to work with.
- Susan Farina, Tax Partner, Price Waterhouse Coopers
What Clients Say
I’m a Senior VP with an accounting and finance background. I’ve worked with lawyers and large law firms. I was referred to Counter to fix a tax dispute. It is very rare to encounter lawyers that combine expertise, dedication, and a businesslike approach to litigation. I have no hesitation in recommending Counter.
- David Cuddy, Senior Vice-President, Finance & Business Operations, CFL
What Accountants Say
Counter Tax Litigators has worked with Fuller Landau to resolve several of our clients’ tax disputes. Counter delivers superior communication.
- Laura Couvrette, CPA, CA, Fuller Landau LLP
What Clients Say
I spent a good part of my career dealing with attorneys on innumerable matters, and found Peter to be extremely competent, open-minded and exceptionally honest. I would not hesitate to use Peter again, and highly recommend the team at Counter Tax Litigators.
- Mark Ram, Retired CEO
What Clients Say
Counter’s representation on our behalf was well informed, professional and efficient, which ultimately resulted in a highly satisfactory decision in all aspects.
- Klaus W. Reif, President, Reif Estate Winery
What Clients Say
I was amazed with the results. They went above and beyond, and I would recommend Counter to any person or business with a significant tax dispute.
- Brian Grott, Northland Screen Corp
Recognition
For nearly 20 years, our leadership in Canadian tax controversy and litigation has earned consistent recognition for expertise, results, and client trust.
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