Peter Aprile 2025

Peter Aprile

Senior Counsel, Tax Litigation

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. 
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, PriceWaterhouseCoopers

Peter is smart, personable, timely and efficient, which are four qualities that don’t always go together! I give Counter my highest recommendation.

- David Daniels, Principal, Daniels Capital Group

Peter Aprile is a very smart, practical tax litigation lawyer. He has successfully assisted my clients. I have no hesitation in recommending Counter Tax Lawyers.

— Mihkel Holmberg, President, Holmberg Watson Professional Group

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. 

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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...