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Jennifer Mak

Associate, Tax Litigation

Jennifer resolves tax controversies with a holistic view to deliver the best overall result.

Jennifer is an associate lawyer at Counter Tax Litigators. Her practice encompasses all aspects of tax controversy and litigation.

Jennifer has represented clients in appeals before the Tax Court of Canada and Federal Court of Canada.  She regularly works on complex objections and audits for private companies and high-net-worth individuals involving international and domestic issues.  

Jennifer has successfully resolved tax controversies involving residence for tax purposes, GST/HST, applications for judicial review, shareholder and employee benefits. 

Jennifer is a mentor with the Federation of Asian Canadian Lawyers. Each year, she helps two Asian Canadian law students navigate the legal profession.  

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

The CRA accepted our submissions and conceded 100% before the hearings. I am so happy with Counter’s representation and the result. Justice has been served and my bruised faith restored.

- Kuldeep Sharma, President, Courtyard by Marriott Toronto/Brampton

There is no ego; just a singular focus on getting the right result. I look forward to continuing to work with the Counter team.

- Vikram Gulati, CPA, CGA

At every step, Counter kept me informed and made practical recommendations. Counter negotiated a settlement that reduced my tax position by 75% and made the Agency drop all the penalties and interest.

- Narinder Seehra, CEO, MSR Holdings Inc.

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Insights

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 - Section 111 of the Income Tax Act (“ITA”) allows taxpayers to carry losses back and forward to offset income in different taxation years. However, subsection 111(5) restricts non-capital loss...

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 to...

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...

Counter Partners' Update Chapter on Corporate Residence Disputes & Strategies

Counter Partners' Update Chapter on Corporate Residence Disputes & Strategies

May 23, 2023 - We’re delighted to announce our newly updated chapter on Corporate Residence & Tax Disputes in Canada (2023), published by Thomson Reuters, is now available.

Management Services, Personal Motives, and the Pursuit of Profit: Brown v. Canada

Management Services, Personal Motives, and the Pursuit of Profit: Brown v. Canada

May 08, 2023 - Thompson Reuters considers the authors “leading tax experts and litigators”. The authors agreed to grant TR partial rights to this work. This article first appeared in TR’s Tax Dispute and Resolution...