James Roberts

James Roberts

Partner

James is a tax litigator powered by his desire to help companies expand and thrive.

James represents private companies and high-net-worth individuals in all aspects of tax litigation. He has appeared at the Tax Court of Canada and the Federal Courts.  

Some recent highlights in James’ tax litigation practice include the following: 

  • Successfully resolved a multi-million-dollar tax dispute for a privately owned and managed international company. James used a litigation strategy that led to a 94 per cent reduction of the disputed amount and yielded a significant litigation ROI.  
  • Met or surpassed the target outcome zone in all matters settled in 2022.  
  • Resolved a tax dispute about non-compliance with foreign reporting requirements, leading to a reduction of over $3M in penalties.  
  • Convinced the CRA to completely abandon its stance on the main intent of a substantial capital investment, saving the taxpayer more than $2M and several years of potential litigation. 

James started his career at Counter Tax Litigators as a summer student in 2016. Since starting at Counter, James has earned his tax and litigation expertise. Leading tax publications publish his tax dispute insights, and he has helped some of Canada’s top private companies win their tax disputes.  

Outside of work, James enjoys spending time with his wife and child. He is also an avid sports fan.

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

Notice of Objection Window | What Carries Forward

Notice of Objection Window | What Carries Forward

A CRA Notice of Reassessment has been issued. The deadline to file a Notice of Objection is now active. Management is deciding how to respond. At this stage, management can still shape the response....

CRA Dispute Record Formation | Decisions Made Before Clarity

CRA Dispute Record Formation | Decisions Made Before Clarity

After a reassessment, management begins making decisions before the full facts and positions are clear. They set an initial view of exposure. They identify the assumptions that support it. They...

CRA Reassessment | What Happens Next

CRA Reassessment | What Happens Next

A CRA Notice of Reassessment sets out the Agency’s position and the amount now assessed. The immediate question is what happens next. Most teams treat what follows as a visible problem: the amount...

Leveraged Growth and the CRA Reassessment Cycle

Leveraged Growth and the CRA Reassessment Cycle

Executive Summary Companies that grow through leveraged acquisitions, refinancing strategies, or complex financing structures eventually encounter the same sequence: CRA audit, reassessment, and...

The Reassessment Decision Window in a CRA Dispute

The Reassessment Decision Window in a CRA Dispute

In large-corporation CRA disputes, management must make consequential decisions immediately after reassessment while information remains incomplete and positions unsettled. This does not reflect a...

Management’s First Explanation in a CRA Dispute

Management’s First Explanation in a CRA Dispute

A CRA dispute begins when CRA issues its reassessment. Management’s first test begins when it explains it to directors, shareholders, lenders, investors, or partners. The structure varies. The...

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