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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The Strategic Choice After Reassessment

Comparing the CRA’s self-adjudication stage with independent oversight in appeal
 

 

 

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Framework Graphic 1 – representing Counter Tax Litigators' integrated approach to client service, combining advanced systems and deep legal expertise to resolve high-stakes tax disputes.

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Insights

Foreign Tax Interest Denied, Tax Court Loss Contained — Bank of Montreal v. HMK

Foreign Tax Interest Denied, Tax Court Loss Contained — Bank of Montreal v. HMK

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The Three Critical Inflection Points in CRA Challenges

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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. ...

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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...

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