Management Services, Personal Motives, and the Pursuit of Profit: Brown v. Canada
May 8, 2023 – How the FCA Evolved the Source-of-income Test and Applied Its Decision in Paletta
Peter focuses on tax litigation, helping businesses and individuals retain the economic value they create.
Peter has dedicated himself to representing Canada’s leading private companies and high-net-worth individuals in tax disputes since 2006.
Throughout this time, he has assisted businesses and individuals in retaining the economic value they create by countering the CRA’s attempts to extract tax revenue. Many recognize him as a leading figure in Canadian tax controversy and litigation.
Peter’s recent work includes:
— Susan Farina, Tax Partner, PriceWaterhouseCoopers
- David Daniels, Principal, Daniels Capital Group
— Mihkel Holmberg, President, Holmberg Watson Professional Group
Peter started his career alongside Richard Fitzsimmons, one of Canada’s top tax litigators. After Richard’s passing, Peter evolved his strategy and approach to tax disputes, culminating in the founding of Counter Tax Litigators.
Outside his professional responsibilities, Peter enjoys times with his wife and two children. A dedicated reader, Peter spends most of this time quietly reading and thinking to understand more.
* Please note that this list does not include some of the matters that we have successfully resolved at the audit stage, objection stage or prior to the hearing of the tax appeal and some of the tax cases that the Tax Court has not released written reasons for judgment.
In Canadian Law Magazine’s 2023 Litigator of the Year category, Peter was recognized as an Excellence Awardee, highlighting his outstanding achievements as a litigator. Judges evaluated the nominees for this prestigious award based on the quantity, quality, importance, and innovativeness of litigation work conducted in 2022.
The Precedent Setter Award recognizes lawyers who are remaking the profession for the better. Peter’s efforts in building Counter into a leading tax-dispute litigation law firm and Counter’s innovation were central to the judges’ decision.
Martindale-Hubbell Peer Review Ratings are the gold standard in lawyer ratings. Peter earned the “AV Preeminent” designation from other top lawyers confirming that Peter is a leading tax litigation lawyer that exemplifies “the highest level of professional excellence”.
ALM Legal Leaders recognized Peter as one of the top rated lawyers in its tax and litigation categories.
Peter was honoured to receive a Fastcase 50 award. The 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.
Martindale-Hubbell conducts ongoing research and surveys including past client interviews. As a result of its research, Martindale-Hubbell awarded Peter its Highest Overall Client Raking.