Framework Graphic 1 – illustrating Counter Tax Litigators' deep tax law expertise, enhanced by its advanced systems and holistic strategies for superior outcomes in high-stakes tax disputes.
Framework Graphic 1 – illustrating Counter Tax Litigators' deep tax law expertise, enhanced by its advanced systems and holistic strategies for superior outcomes in high-stakes tax disputes.

A Comprehensive Analysis of Income Tax Penalties

Update to the leading guide on penalties under the Income Tax Act, published by Counter Tax Litigators LLP x Thomson Reuters.

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

CRA In-Audit Conflict: Managing Risk & Control

CRA In-Audit Conflict: Managing Risk & 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,...

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...

CRA's Objection Process: Full Engagement vs. Strategic Disengagement

CRA's Objection Process: Full Engagement vs. Strategic Disengagement

November 04, 2024 - When you receive a Notice of Reassessment (NoR) from the CRA and decide to contest it, one strategic choice significantly influences both the resources you commit and the outcome: selecting the most...

A Comprehensive Analysis of Income Tax Penalties in Canada

A Comprehensive Analysis of Income Tax Penalties in Canada

October 17, 2024 - Counter Tax Litigators LLP is excited to announce the updated Practical Insight on Penalties under the Income Tax Act (2024), authored by Peter Aprile, James Roberts, and Jennifer Mak, and published...

Federal Court Sets Higher Bar for CRA: A Win for Taxpayers in Disputes

Federal Court Sets Higher Bar for CRA: A Win for Taxpayers in Disputes

October 04, 2024 - The Federal Court of Canada’s decision in Onex Corporation v. Canada (Attorney General)[1] highlights a meaningful development for taxpayers challenging the Agency’s discretionary decisions. The FC’s...

Cryptocurrency Wealth and Departure from Canada

Cryptocurrency Wealth and Departure from Canada

June 14, 2024 - Cryptocurrencies have redefined wealth creation but also bring unprecedented challenges for tax planning and compliance. As cryptocurrency values soar and governments worldwide heighten scrutiny,...

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.

How can we help you?