Peter Aprile

Career

Peter Aprile is Partner and Head of Tax Controversy & Litigation at Counter Tax Litigators LLP. He focuses exclusively on high-stakes tax disputes, applying judgment and discipline to resolve them effectively.

He has acted in significant matters before the Tax Court of Canada and the Federal Court, advising executives and boards in disputes that threaten capital and test executive focus and control. His work spans GAAR challenges, issues related to the purpose of borrowing, surplus stripping controversies, and residency matters, including non-resident trusts, departure tax, and treaty interpretation.

Peter and the firm have been recognized in Chambers Canada, International Tax Review, and the Canadian Law Awards for excellence in high-stakes tax controversy and litigation.

Professional Memberships

Tax Court Bench and Bar Committee (Executive), Canadian Tax Foundation, Advocates’ Society, Canadian Bar Association

Practice Areas

Tax Controversy and Litigation

Publications

Regular contributor to Thomson Reuters’ Tax Disputes & Resolution Centre, including chapters on corporate residence, judicial review, and income tax penalties.

Author of numerous articles and commentary on tax controversy in industry outlets, covering topics such as non-resident trusts, purpose-of-borrowing disputes, GAAR, and surplus-stripping controversies.

Frequent speaker and writer on tax dispute strategy and risk management.