CRA’s Objection Process: Full Engagement vs. Strategic Disengagement
Key Considerations for Choosing the Most Effective Process
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
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.
Services
* 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.
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...