NW Croppped

Natalie Worsfold

Partner, Tax Litigation

Natalie’s excellence in tax litigation protects against CRA overreach.  

Since 2008, Natalie has dedicated her practice exclusively to resolving tax disputes, providing trusted expertise to private company CEOs and high-net-worth individuals.  

Natalie consistently devises innovative litigation strategies, and she has achieved highly favourable outcomes for numerous clients.  

Natalie has:

  • Overturned a CRA assessment for a $20 million investment portfolio from business income to lower-tax capital transactions;
  • Protected the personal interests of corporate directors by shielding them from more than $13 million in HST charges following a corporate merger;
  • Successfully challenged CRA reassessments that were denying SR&ED credits and ensured the recognition of similar SR&ED credits for the long term, a vital component of the business's long-term strategy and feasibility;
  • Dismantled the CRA's valuation of a property and protected the taxpayer from a $1.7 million tax liability;
  • Overturned the CRA's classification and valuation of mining equipment and supplies, leading to savings of over $3 million;
  • Demolished CRA's allegations of $10M+ of unreported income and taxable shareholder benefits;
  • Overturned the CRA's reassessment and attempt to use the anti-avoidance rules to nullify a legitimate tax planning strategy connected to a low-tax jurisdiction.

Natalie regularly presents on tax matters and contributes articles, sharing her expertise in tax avoidance, shareholder benefits, and various tax issues. She also offers her insights on different methods to create advantages in tax disputes. And she has developed courses to teach tax litigators about early case assessment, strategy in litigation, and decision science. 

Natalie also offers mentorship and coaching to litigation lawyers and rising stars outside of Counter’s team, fostering growth and litigation excellence within the broader legal community. 

Latest Insights

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.