Jennifer S.M. Mak

Nov 28, 2024 | mondaq.com | James Roberts |Jennifer S.M. Mak

How Onex v. Canada Helps Taxpayers Challenge CRA Decisions 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 ruling sets a higher standard for the Canada Revenue Agency, requiring it to more carefully consider and justify its interpretations when they result in significant consequences for taxpayers.

Aug 6, 2024 | mondaq.com | Peter Aprile |James Roberts |Jennifer S.M. Mak

CT Counter Tax Litigators More Counter is a Toronto-based law firm that specializes in resolving tax controversies across Canada. Canada's leading privately-owned companies and high-net-worth individuals trust us to deliver superior outcomes and clarity along the way. Our leading tax litigators use our tax dispute systems for better results. Our framework boosts our lawyers' expertise, making our service offer unique.

Aug 1, 2024 | mondaq.com | Peter Aprile |James Roberts |Jennifer S.M. Mak

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 by Thomson Reuters in its Tax Disputes & Resolution Centre, is now available. The Canada Revenue Agency's legislation, case rulings, and stances are constantly changing. Navigating these shifts and uncertainties is crucial in this evolving field.

Aug 1, 2024 | mondaq.com | Peter Aprile |James Roberts |Jennifer S.M. Mak

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 by Thomson Reuters in its Tax Disputes & Resolution Centre, is now available. The legislation, case rulings, and stances of the Canada Revenue Agency are constantly changing. Navigating these shifts and uncertainties is crucial in this evolving field.

Sep 27, 2023 | canadian-accountant.com | Peter Aprile |Natalie Worsford |James Roberts |Jennifer S.M. Mak

Practice National Taxation The courts will increasingly gravitate toward the minority approach in the Deans Knight decision, assert the tax lawyers of Counter Tax Litigators Peter Aprile is the founder of and a partner, specializing in tax dispute resolution and litigation, at Counter Tax Litigators. SECTION 111 of theIncome Tax Act("ITA") allows taxpayers to carry losses back and forward to offset income in different taxation years.