Peter Aprile

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Articles

Avoiding And Navigating Tax Disputes In The Mining Sector

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.
A Comprehensive Analysis Of Income Tax Penalties In Canada

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.
Overturning CRA Penalty Assessments

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.
Tax Disputes & ITC Claim Protection When Suppliers Fall Short

Nov 23, 2023 | mondaq.com | Peter Aprile |James Roberts

Key Takeaways for CEOs and CFOs from Fiera Foods Tax Court Ruling The Tax Court of Canada's recent ruling in Fiera Foods Company v. HMK1 has significant implications for businesses claiming Input Tax Credits (ITCs) under the Excise Tax Act (ETA). The Tax Court sided with Fiera Foods, affirming its right to claim ITCs for HST paid to staffing agencies supplying temporary workers.
Deans Knight will have a serious impact on tax planning & tax disputes

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.
Deans Knight Will Have A Serious Impact On Tax Planning & Tax Disputes

Sep 21, 2023 | mondaq.com | Peter Aprile |Natalie Worsfold |James Roberts |Jennifer S.M. Mak

Section 111 of the Income Tax Act ("ITA") allows taxpayers to carry losses back and forward to offset income in different taxation years. However, subsection 111(5) restricts non-capital loss carryovers for a corporation if there is a change in control, and the new owners do not continue the same or similar business that incurred the losses. In Deans Knight Income Corp. v.
Management Services, Personal Motives, And The Pursuit Of Profit: Brown V. Canada

Jun 7, 2023 | mondaq.com | Peter Aprile |Natalie Worsfold |James Roberts

Thompson Reuters considers the authors "leading tax experts and litigators". The authors agreed to grant TR partial rights to this work. This article first appeared in TR's Tax Dispute and Resolution Centre. In Brown v. Canada 2022 FCA 200, the Federal Court of Appeal restated the source-of-income test and applied the test to the taxpayer's management services activity.
Peter Aprile

Apr 20, 2023 | canadian-accountant.com | Peter Aprile

Peter Aprile is a partner, specializing in tax dispute resolution and litigation, at Counter Tax Litigators.
One way CPAs leak confidential information to the CRA

Apr 20, 2023 | canadian-accountant.com | Peter Aprile

Practice National Accountants that unthinkingly send the Agency tax appeal invoices improperly reveal solicitor-client communications and more Apr 21, 2023 Author: Peter Aprile GENERALLY speaking, taxpayers can deduct fees and costs paid to prevent a potential assessment or dispute a reassessment under paragraph 60(o)(i) of the Income Tax Act R.S.C. 1985, c. 1 (the “ITA”). We encourage our clients to deduct these fees and costs.