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Mid-Market CFOs: Managing CRA Audit Risk

Strategies CFOs can implement to minimize CRA audit exposure and improve defensibility without disrupting operations.
Counter Tax Litigators LLP expertise in tax controversy and litigation, representing successful companies and high-net-worth individuals in CRA disputes
Tax partner from Price Waterhouse Coopers commending Peter Aprile and the Counter Tax Litigators team for their hands-on, focused, and diligent approach to tax law.

What Accountants Say

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, Price Waterhouse Coopers

Senior VP client with an accounting and finance background praising Counter Tax Litigators for their expertise, dedication, and businesslike approach to tax dispute litigation.

What Clients Say

I’m a Senior VP with an accounting and finance background. I’ve worked with lawyers and large law firms. I was referred to Counter to fix a tax dispute. It is very rare to encounter lawyers that combine expertise, dedication, and a businesslike approach to litigation. I have no hesitation in recommending Counter.

- David Cuddy, Senior Vice-President, Finance & Business Operations, CFL

Accountant representing Fuller Landau LLP praising Counter Tax Litigators for superior communication in resolving client tax disputes.

What Accountants Say

Counter Tax Litigators has worked with Fuller Landau to resolve several of our clients’ tax disputes. Counter delivers superior communication.

- Laura Couvrette, CPA, CA, Fuller Landau LLP

Retired CEO client recommending Peter Aprile and the Counter Tax Litigators team for their competence, honesty, and exceptional handling of legal matters.

What Clients Say

I spent a good part of my career dealing with attorneys on innumerable matters, and found Peter to be extremely competent, open-minded and exceptionally honest. I would not hesitate to use Peter again, and highly recommend the team at Counter Tax Litigators.

- Mark Ram, Retired CEO

Successful business leader praising Counter Tax Litigators’ team for their professional, efficient representation, leading to a highly satisfactory decision.

What Clients Say

Counter’s representation on our behalf was well informed, professional and efficient, which ultimately resulted in a highly satisfactory decision in all aspects.

- Klaus W. Reif, President, Reif Estate Winery

Business leader praising the Counter Tax Litigators team for going above and beyond in handling a significant tax dispute.

What Clients Say

I was amazed with the results. They went above and beyond, and I would recommend Counter to any person or business with a significant tax dispute.

- Brian Grott, Northland Screen Corp

Recognition

Our law firm and tax lawyers regularly receive
recognition as leaders in tax controversy and litigation.

Insights

Mid-Market CFOs: Managing CRA Audit Risk Strategies

Mid-Market CFOs: Managing CRA Audit Risk Strategies

March 05, 2025 - This article is part of CFO Tax Dispute Insights, Counter Tax Litigators LLP’s executive series delivering strategic guidance to mid-market businesses and CFOs on navigating high-stakes CRA disputes,...

The CRA’s Tax Earned by Audit Metric & March 31st Target: A System for Tax Disputes

The CRA’s Tax Earned by Audit Metric & March 31st Target: A System for Tax Disputes

February 28, 2025 - Key Takeaways Data shows a surge in improper CRA reassessments leading up to March 31, driven by TEBA targets and March 31 fiscal year-end pressures. CRA audits, driven by TEBA targets,...

CRA In-Audit Conflict: Managing Risk & Taking Control

CRA In-Audit Conflict: Managing Risk & Taking Control

February 21, 2025 - Key Takeaways for Leaders A CRA audit is not just a process - it's a conflict, unfolding in real-time. Leaders who treat it as routine compliance fail to recognize the trends, the CRA's approach,...

The Evolving Landscape of Supply Classification

The Evolving Landscape of Supply Classification

February 14, 2025 - Key Challenge: Clarifying GST/HST Supply Classification Integrated Transactions: Tax professionals should proactively evaluate whether elements of a purchase are truly independent or part of a...

Offshore Asset & T1135 Risk: Azmayesh-Fard v HMK & Strategic Dispute Planning

Offshore Asset & T1135 Risk: Azmayesh-Fard v HMK & Strategic Dispute Planning

February 13, 2025 - Key Takeaways from Azmayesh-Fard v HMK Enforcement is accelerating. CRA’s access to global financial data has fundamentally changed how offshore holdings are detected. Risk is dynamic. Proactive...

Choose the Right Beneficiary to Avoid Tax Pitfalls

Choose the Right Beneficiary to Avoid Tax Pitfalls

February 06, 2025 - The Federal Court of Appeal’s (“FCA”) decision in Enns v. Canada[1] clarifies how “spouse” is defined for purposes of paragraph 160(1)(a) of the Income Tax Act (“ITA”). This decision carries...

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