James Roberts and the Counter Tax Litigators team for their hands-on, strategic approach to tax dispute resolution.

James Roberts

Partner, Tax Litigation

James is a tax litigator powered by his desire to help companies expand and thrive.

James represents private companies and high-net-worth individuals in all aspects of tax litigation. He has appeared at the Tax Court of Canada and the Federal Courts.  

Some recent highlights in James’ tax litigation practice include the following: 

  • Successfully resolved a multi-million-dollar tax dispute for a privately owned and managed international company. James used a litigation strategy that led to a 94 per cent reduction of the disputed amount and yielded a significant litigation ROI.  
  • Met or surpassed the target outcome zone in all matters settled in 2022.  
  • Resolved a tax dispute about non-compliance with foreign reporting requirements, leading to a reduction of over $3M in penalties.  
  • Convinced the CRA to completely abandon its stance on the main intent of a substantial capital investment, saving the taxpayer more than $2M and several years of potential litigation. 
I’m a Senior VP who has previously hired large law firms. I was referred to Counter to fix a tax dispute from the sale of an investment property I co-owned with two non-residents. I wish I hired Counter sooner.

- David Cuddy, Senior Vice-President, Finance & Business Operations, CFL 

Natalie, James and Jennifer have been wonderful to work with for our numerous legal cases. They understand there’s a job to be done and they get it done with minimal fuss and detailed written follow-up.

- Verified Client Feedback for the Legal 500: 2024 Elite Tax Boutique Award

Counter delivered superior communication, high-quality submissions and a great result.

- Laura Couvrette, CPA, CA, Fuller Landau LLP 

James started his career at Counter Tax Litigators as a summer student in 2016. Since starting at Counter, James has earned his tax and litigation expertise. Leading tax publications publish his tax dispute insights, and he has helped some of Canada’s top private companies win their tax disputes.  

Outside of work, James enjoys spending time with his wife and child. He is also an avid sports fan.

Latest Insights

CounterMeasure: IA built to win tax appeals

Nov 22, 2016

The fine line that separates winning and losing a tax dispute

Apr 18, 2016

Gaining a competitive advantage in tax appeals

Jan 22, 2016

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CRA’s Objection Process: Full Engagement vs. Strategic Disengagement

Key Considerations for Choosing the Most Effective Process

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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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Insights

A Comprehensive Analysis of Income Tax Penalties in Canada

A Comprehensive Analysis of Income Tax Penalties in Canada

July 17, 2024 - Counter Tax Litigators LLP is excited to announce the updated Practical Insight on Penalties under the Income Tax Act (2024), authored by Peter Aprile, James Roberts, and Jennifer Mak, and published...

Avoiding and Navigating Tax Disputes in the Mining Sector

Avoiding and Navigating Tax Disputes in the Mining Sector

January 21, 2024 - In Glencore Canada Corporation v. His Majesty the King[1](“Glencore FCA”), the Federal Court of Appeal examined and ultimately rejected Glencore’s contention regarding the tax treatment of...

Tax Disputes & ITC Claim Protection When Suppliers Fall Short

Tax Disputes & ITC Claim Protection When Suppliers Fall Short

November 17, 2023 - The Tax Court of Canada’s recent ruling in Fiera Foods Company v. HMK1 has significant implications for businesses claiming Input Tax Credits (ITCs) under the Excise Tax Act (ETA).

Deans Knight Will Have a Serious Impact on Tax Planning & Tax Disputes

Deans Knight Will Have a Serious Impact on Tax Planning & Tax Disputes

September 07, 2023 -

Mining in the Tax Court: Glencore’s Challenge to Exclude Fees from Taxable Income

Mining in the Tax Court: Glencore’s Challenge to Exclude Fees from Taxable Income

July 05, 2023 - Key Points in Glencore The case involves an appeal against a reassessment under the Income Tax Act, where the Minister of National Revenue assessed as income certain fees Falconbridge received due...

When Insurance Premiums Lead to Unwanted Shareholder Benefits

When Insurance Premiums Lead to Unwanted Shareholder Benefits

June 08, 2023 - Management M.-A. Roy Inc. v. HMK (“Gestion Roy”) centers around whether an Opco’s decision to pay insurance premiums, with two Holdcos as the policy owners, gives rise to a shareholder benefit under...

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