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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.  
 
Additionally, Natalie leads Counter’s ‘1% for Good’ pro bono initiative, leveraging her in-depth tax and litigation expertise and passion for justice. At this time, the ‘1% for Good’ initiative is pursuing projects that will increase CRA and DoJ accountability. 

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Insights

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...

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

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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...

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.