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.
Bar Admission
- Ontario, 2008
Language
- English
Education
- AIPMM, Certified Product Manager, 2019
- University of Toronto, Lean Six Sigma Certification, 2018
- Federation of Law Societies of Canada, Certificate of Qualification, 2007
- University of Bristol, UK, Bachelor of Law, 2004
- A-One Cakes & Pastries Inc. v. Her Majesty the Queen, 2021-1904(IT)G
- 1532690 Ontario Ltd. v. Her Majesty the Queen, 2019-846(IT)G, 2019-1284(GST)G
- Dendres Corp. v. Her Majesty the Queen, 2019-232(IT)G
- 2070403 Ontario Inc. v. Her Majesty the Queen, 2019-148(IT)G
- Campbellford Wholesale Company Limited v. Her Majesty the Queen, 2018-4364(GST)G
- Piller Investments Ltd. v. Her Majesty the Queen, 2016-4884(IT)G
- Ghooparaloo v. Her Majesty the Queen, 2018-2079(IT)G
- Bolen v. Her Majesty the Queen, 2016-4622(IT)G
- Lancaster Developments Ltd. v. Her Majesty the Queen, 2015-5476(GST)G
- Tiraspolskiy v. Her Majesty the Queen, 2015-4545(IT)G
- Ghazvini v. Her Majesty the Queen, 2015-4416(IT)G
- Cuddy v. Her Majesty the Queen, 2015-3020(IT)G
- Williams v. Her Majesty the Queen, 2015-1050(IT)G
- Fit Design & Build Inc. v. Her Majesty the Queen, 2014-861(IT)G
- Schunk v. Her Majesty the Queen, 2014-718(IT)G
- Partner Logistics Solutions Inc. v. Her Majesty the Queen, 2012-4709(GST)G
- Doyscher v. Her Majesty the Queen, 2012-4690(IT)G
- Technical Management Consultants Inc. v. Her Majesty the Queen, 2012-4654(IT)G
- Gamble v. Her Majesty the Queen, 2010-2824(IT)G
- Canadian Tax Foundation
- Ontario Bar Association Tax Group
- Lawyers for Fair Taxation
- Taxpayers Advocate
- Society of Decision Professionals
- Project Management Institute
- Legal Innovation Zone
- Toronto Legal Innovators Roundtable
- She Breaks the Law
- Canadian Association of Women Entrepreneurs and Executives
- Toronto Lawyers Association
- The Advocate’s Society
- Canadian businesses face adversarial audits as Canada Revenue Agency expands powers
- You’ve been flagged for a CRA audit. Here’s what happens next
- How individuals and business owners can minimize the chance of a CRA audit
- Inside N.S. businessman John Risley's huge tax fight with the CRA
- Proposed CRA audit powers sound alarms
- Lexpert Rising Star Awards celebrates more than lawyer's legal skills, past winner Natalie Worsfold
- Lexpert Rising Star: Natalie Worsfold
- Women in Law: The Future of Law
- Tax Litigation: Proving Your Case Workshop, The Advocate’s Society (2025)
- The Future of Law and Legal Tech, Women in Law Canada Summit (2023)
- Using Decision Science, Society of Decision Professionals (2022)
- Decision Science 101, Decision Analysis Affinity Group (2021)
- Winning Better Litigation Results, Canadian Litigation Forum (2019)
- Litigation Risk Assessment: Settlement Strategy and Offers, Ontario Bar Association (2019)
- Better Risk Assessment for Litigators, Legal Talk Network (2019)
- Strategic Litigation Solutions, Law Society of Ontario (2019)
- Better Litigation Results & Process Mapping, Ontario Bar Association (2019)
- Using Technology to be the Best Litigator, Lawyers Daily (2019)
- Building a Client-Centric Law Firm, Lawyerist (2018)
- Building a Complete Law Firm, Clio Conference (2017)
Natalie’s accomplishments were recognized with the Lexpert Rising Stars: Leading Lawyers Under 40.
This award honours lawyers who have made outstanding contributions in their careers. It is voted on by an advisory panel of leading legal experts.
Natalie was featured in the Society of Decision Professionals’ Member Spotlight for 2022.
The Society of Decision Professionals (SDP), a membership organization dedicated furthering the practice of decision analysis and decision quality. SDP is currently the only certifying body for decision professionals.
Natalie was honored to receive a Fastcase 50 Award in 2020.
Fastcase 50 is an international award that recognizes lawyers, legal technologists, and judges who inspire others in the legal industry through their intelligence, creativity, and leadership.
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Insights
November 25, 2025 - Key Takeaways Loss consolidation transactions attract CRA scrutiny even when they align with Parliament’s design. The mechanical structure rarely drives the dispute – the interpretive record does.
November 24, 2025 - Key Takeaways Penn Ventilator v. HMQ shows how disputes evolve when a transaction supports two viable case theories: one tied to the structure, the other to the business’s economic behaviour. ...
November 24, 2025 - Key Takeaways Inconsistent cross-border descriptions created tension between the structure’s design and its economic reality. Risk and benefit flowed to different entities across jurisdictions,...
November 03, 2025 - Key Points CRA can now compel sworn questioning. The Income Tax Act authorizes auditors to require oral testimony under oath during audits, bringing executives directly into the record. Early...
October 29, 2025 - Key Takeaways CRA challenges often evolve from mechanical to interpretive tests. The decisive factor is not a structure’s mechanics but whether its interpretive elements hold up under scrutiny. ...
September 22, 2025 - Key Takeaways The Tax Court confirmed that foreign tax interest is not deductible — BMO lost on the law. The result was predictable, but BMO's strategy maximized potential upside while containing...





