Peter Aprile 2025

Peter Aprile

Senior Counsel, Tax Litigation

Peter focuses on tax litigation, helping mid-market businesses and affluent families 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. 

Additionally, Peter leads Counter’s ‘1% for Good’ impact initiative. This pro bono initiative engages in projects aimed at transforming the Canadian tax dispute system, focusing on increasing accountability within the CRA and the DoJ.

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 time with his wife and two children. A dedicated reader, Peter spends most of this time quietly reading and thinking to understand more. 

Latest Insights

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The Strategic Choice After Reassessment

Comparing the CRA’s self-adjudication stage with independent oversight in appeal
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Insights

GAAR and Economic Reality: When Imperfect Structures Survive Scrutiny

GAAR and Economic Reality: When Imperfect Structures Survive Scrutiny

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...

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

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...

Tips for Accountants Navigating Audits: Part 3

Tips for Accountants Navigating Audits: Part 3

Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability.One of the chapters in RTD3...

Tips for Accountants Navigating Audits: Part 2

Tips for Accountants Navigating Audits: Part 2

Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability.One of the chapters in RTD3...

Tips for Accountants Navigating Audits: Part 1

Tips for Accountants Navigating Audits: Part 1

Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability.One of the chapters in RTD3...

Navigating Unintended Tax Effects: Limited Rescission & Other Options

Navigating Unintended Tax Effects: Limited Rescission & Other Options

The Supreme Court of Canada, in Canada (Attorney General) v. Collins Family Trust,1 further clarifies when courts can grant equitable remedies of rectification or rescission.

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