The Strategic Choice After Reassessment
Comparing the CRA’s self-adjudication stage with independent oversight in appeal
Our People
Our tax lawyers deliver superior results
and clarity along the way.
Insights
September 07, 2025 - Peter Aprile, Senior Counsel at Counter LLP, describes three inflection points that define how CRA challenges develop and are resolved. The framework reflects insights drawn from years of...
September 03, 2025 - The Shared Challenge Counsel on both sides of tax disputes face the same challenge: how to resolve cases in ways that are fair, objective, and justifiable — settlements that withstand internal and...
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...
What Accountants Say
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, Price Waterhouse Coopers
What Clients Say
I’m a Senior VP with an accounting and finance background. I’ve worked with lawyers and large law firms. I was referred to Counter to fix a tax dispute. It is very rare to encounter lawyers that combine expertise, dedication, and a businesslike approach to litigation. I have no hesitation in recommending Counter.
- David Cuddy, Senior Vice-President, Finance & Business Operations, CFL
What Accountants Say
Counter Tax Litigators has worked with Fuller Landau to resolve several of our clients’ tax disputes. Counter delivers superior communication.
- Laura Couvrette, CPA, CA, Fuller Landau LLP
What Clients Say
I spent a good part of my career dealing with attorneys on innumerable matters, and found Peter to be extremely competent, open-minded and exceptionally honest. I would not hesitate to use Peter again, and highly recommend the team at Counter Tax Litigators.
- Mark Ram, Retired CEO
What Clients Say
Counter’s representation on our behalf was well informed, professional and efficient, which ultimately resulted in a highly satisfactory decision in all aspects.
- Klaus W. Reif, President, Reif Estate Winery
What Clients Say
I was amazed with the results. They went above and beyond, and I would recommend Counter to any person or business with a significant tax dispute.
- Brian Grott, Northland Screen Corp
Recognition
For nearly 20 years, our leadership in Canadian tax controversy and litigation has earned consistent recognition for expertise, results, and client trust.
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