Peter Aprile

Peter Aprile

Partner

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

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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