Counter Tax Litigators LLP

Counter Tax Litigators LLP practices exclusively in Canadian tax controversy and litigation. The firm represents executives and private companies in high-stakes disputes with the Canada Revenue Agency, often involving large-corporation rules under the Income Tax Act and board-level exposure.

Approach

The firm’s lawyers bring deep expertise in Canadian tax litigation. That expertise is applied within a codified system that sets the quality standard for every stage of a dispute. At each stage, lawyers produce their work within the system: identifying gaps, surfacing opportunities, and challenging assumptions. Depending on stage, the process may stress-test case theories, align strategy with execution, or frame negotiation scenarios into resolution pathways and quantified ranges. Lawyers and system together produce decision-ready reports for boards and committees. The framework applies consistent rigour across matters, regardless of complexity, timing, or personnel.

Representative Work (anonymized)

• Canada–U.K. residency dispute involving departure tax and treaty protection.
• Purpose-of-borrowing controversy in a private equity–backed Canadian company with board-level implications.
• GAAR dispute arising from surplus-stripping transactions.
• Multi-year CRA reassessment requiring staged resolution planning and board reporting.
• Withholding tax dispute on cross-border dividend payments.
• Loss utilization challenge material to financing and governance optics.

International Work

Counter LLP frequently advises on disputes with cross-border dimensions that affect executives and private companies, including residency determinations, departure tax issues, non-resident trust disputes, and treaty matters. These disputes often carry executive-level exposure and require strategies that balance technical arguments with board-level credibility.

Recognition

Counter LLP is recognized as one of Canada’s leading tax litigation practices. Counter LLP and its lawyers are ranked in Chambers Canada and have been named finalists and awardees by International Tax Review and the Canadian Law Awards for excellence in high-stakes tax controversy and litigation.

Key Contacts

Managing Partner: Natalie Worsfold | [email protected]

Practice Leader: Peter Aprile | [email protected]