CRA’s Objection Process: Full Engagement vs. Strategic Disengagement
Key Considerations for Choosing the Most Effective Process
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:
- Jim & Yvonne Schunk, Private Business Owners
- Yuriy Tiraspolskiy, President , Consagro Inc.
- 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.
Natalie’s accomplishments were recognized with the Lexpert Rising Stars: Leading Lawyers Under 40.
This award honours lawyers who have made outstanding contributions in their careers. It is voted on by an advisory panel of leading legal experts.
Natalie was featured in the Society of Decision Professionals’ Member Spotlight for 2022.
The Society of Decision Professionals (SDP), a membership organization dedicated furthering the practice of decision analysis and decision quality. SDP is currently the only certifying body for decision professionals.
Natalie was honored to receive a Fastcase 50 Award in 2020.
Fastcase 50 is an international award that recognizes lawyers, legal technologists, and judges who inspire others in the legal industry through their intelligence, creativity, and leadership.
Key Considerations for Choosing the Most Effective Process
August 21, 2025 - Key Takeaways Benefit without cost invites scrutiny: Courts scrutinize tax structures that offer benefit without tradeoff, and when they find this gap, they side with the CRA and uphold the...
August 14, 2025 - Key Takeaways No inference of intent: Courts rejected the claim that surplus cash was earmarked for decommissioning in the absence of contemporaneous reserves, allocations, or disclosures. ...
August 11, 2025 - Key Insights at a Glance Deferral as strategy: Departure tax can be deferred without interest when acceptable security is posted, preserving liquidity during transition. Forms of security: CRA...
June 30, 2025 - Key Takeaways Forum defines outcomes: The taxpayer’s appeal was quashed without the merits ever being heard because the chosen forum lacked jurisdiction. Procedure equals substance: Courts...
June 05, 2025 - Key Takeaways Framing gap: The Tax Court accepted CRA’s framing because Vortex’s reply lacked engineering support and legal positioning. In other disputes, when claims were framed with qualified...
April 15, 2025 - Key Takeaways Premium payments as benefits: When one company pays premiums on a policy owned by another, courts treat it as a taxable benefit — intent does not override structure. Expanding...