Peter_Square

Peter Aprile

Partner, Tax Litigation

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:  

  • acting for a corporate group facing a $27 million tax dispute related to whether some subsidiaries were Canadian resident corporations. This matter includes 12 Tax Court appeals and a Federal Court application.  
  • resolving four tax appeals related to non-compliance for overseas asset reporting. Peter worked to set a target outcome for each taxpayer based on a realistic application of the law to the facts and exceeded the expected outcome in all four cases. Peter's work saved the clients over $4.2 million.  
  • successfully negotiating a settlement for five Tax Court appeals related to a private company and its shareholders. Peter's work reduced the group’s tax assessments by 91 per cent. 
  • successfully persuading the CRA to abandon its position related to taxation of overseas income and saving a client $2.3 million. 
Peter Aprile is a very hands on and practical tax lawyer who is very focused and diligent. He is a pleasure to work with.

— Susan Farina, Tax Partner, PriceWaterhouseCoopers

Peter is smart, personable, timely and efficient, which are four qualities that don’t always go together! I give Counter my highest recommendation.

- David Daniels, Principal, Daniels Capital Group

Peter Aprile is a very smart, practical tax litigation lawyer. He has successfully assisted my clients. I have no hesitation in recommending Counter Tax Lawyers.

— 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. 

How can we help you?

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...