NW Croppped

Natalie Worsfold

Partner, Tax Litigation

Natalie’s excellence in tax litigation protects against CRA overreach.  

Since 2008, Natalie has dedicated her practice exclusively to resolving tax disputes, providing trusted expertise to private company CEOs and high-net-worth individuals.  

Natalie consistently devises innovative litigation strategies, and she has achieved highly favourable outcomes for numerous clients.  

Natalie has:

  • Overturned a CRA assessment for a $20 million investment portfolio from business income to lower-tax capital transactions;
  • Protected the personal interests of corporate directors by shielding them from more than $13 million in HST charges following a corporate merger;
  • Successfully challenged CRA reassessments that were denying SR&ED credits and ensured the recognition of similar SR&ED credits for the long term, a vital component of the business's long-term strategy and feasibility;
  • Dismantled the CRA's valuation of a property and protected the taxpayer from a $1.7 million tax liability;
  • Overturned the CRA's classification and valuation of mining equipment and supplies, leading to savings of over $3 million;
  • Demolished CRA's allegations of $10M+ of unreported income and taxable shareholder benefits;
  • Overturned the CRA's reassessment and attempt to use the anti-avoidance rules to nullify a legitimate tax planning strategy connected to a low-tax jurisdiction.
Natalie calculated the financial impact of every outcome, kept us informed of the progress, and explained the route that would lead to the best return on our legal fees.

- Jim & Yvonne Schunk, Private Business Owners

Peter's and Natalie's deep and unique expertise and disciplined approach carved out a competitive edge for us during our tax dispute. We recommend Counter to any mid-sized company facing a significant tax dispute.

- Yuriy Tiraspolskiy, President , Consagro Inc.

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

Natalie regularly presents on tax matters and contributes articles, sharing her expertise in tax avoidance, shareholder benefits, and various tax issues. She also offers her insights on different methods to create advantages in tax disputes. And she has developed courses to teach tax litigators about early case assessment, strategy in litigation, and decision science. 

Natalie also offers mentorship and coaching to litigation lawyers and rising stars outside of Counter’s team, fostering growth and litigation excellence within the broader legal community. 

Latest Insights

Insights

The Standards That Enable Settlement in Tax Disputes

The Standards That Enable Settlement in Tax Disputes

September 03, 2025 - This article appeared in Thomson Reuters’ Tax Disputes & Resolution Centre, alongside leading resources on managing complex tax controversies.

The Strategic Choice After Reassessment

The Strategic Choice After Reassessment

November 04, 2024 - When CRA issues a Notice of Reassessment (NoR), taxpayers who contest it face a structural choice: remain in CRA’s self-adjudication stage at objection, or transition to the Tax Court’s independent...

GAAR and Economic Reality: When Imperfect Structures Survive Scrutiny

GAAR and Economic Reality: When Imperfect Structures Survive Scrutiny

April 08, 2024 - Key Takeaways Economic substance framed: The FCA upheld a constrained structure because it was positioned around real economic gains, not technical form. Whole-plan control: GAAR outcomes often...

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...