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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 calculated the financial impact of every outcome, kept us informed of the progress, and explained the route that would lead to the best return on our legal fees.

- Jim & Yvonne Schunk, Private Business Owners

Peter's and Natalie's deep and unique expertise and disciplined approach carved out a competitive edge for us during our tax dispute. We recommend Counter to any mid-sized company facing a significant tax dispute.

- Yuriy Tiraspolskiy, President , Consagro Inc.

There is no ego; just a singular focus on getting the right result. I look forward to continuing to work with the Counter team.

- Vikram Gulati, CPA, CGA

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. 

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Insights

Mutual Fund Trust Disputes: When Form Without Execution Collapses

Mutual Fund Trust Disputes: When Form Without Execution Collapses

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...

Surplus Cash and the Active Asset Test: Lessons from Ehresman

Surplus Cash and the Active Asset Test: Lessons from Ehresman

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. ...

Strategic Deferral of Departure Tax: Security, Liquidity, and Control

Strategic Deferral of Departure Tax: Security, Liquidity, and Control

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...

Transfer Pricing Disputes: How Forum Choice Alters Outcomes

Transfer Pricing Disputes: How Forum Choice Alters Outcomes

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...

Framing Gaps in SR&ED Disputes Shift Control to CRA

Framing Gaps in SR&ED Disputes Shift Control to CRA

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...

Hidden Tax Risks in Corporate Life Insurance

Hidden Tax Risks in Corporate Life Insurance

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...