ARTICLE
1 August 2024

Overturning CRA Penalty Assessments

CT
Counter Tax Litigators

Contributor

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. Although the framework's purpose is to increase competency and clarity, it results in efficiency gains too. Managing complexity and risk is essential to achieve exceptional results when dealing with a tax dispute. Together, our people and expert systems amplify our teams' and clients' capabilities, leading to more effective collaboration and better results.
Update to the leading guide on penalties under the Income Tax Act, published by Counter Tax Litigators LLP x Thomson Reuters.
Canada Tax
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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. This comprehensive guide offers insights into the intricate realm of penalties.

Counter Tax Litigators LLP invites readers to explore this updated Practical Insight, now embedded in the announcement, and gain a deeper understanding of penalties under the Income Tax Act.

Overturning Penalties and Providing Clarity

"Overturning penalties under the Income Tax Act requires experience and a deep understanding of the legislation and case law," said Peter Aprile, Senior Counsel, Tax Controversy and Litigation at Counter Tax Litigators LLP.

"We continually strive to enhance our knowledge and capabilities to effectively challenge the CRA's imposition of penalties. Working on this update has furthered our expertise, and we hope it will expand our clients' and their advisors' understanding and prove valuable."

In the Updated Practical Insight, Readers Will Find:

  • Comprehensive Overview of Civil Penalties Under the Income Tax Act: Including non-discretionary, gross-negligence, and third-party penalties.
  • In-depth Analysis: Detailed examination of the legal criteria and defences available to taxpayers.
  • Practical Strategies: Effective approaches to address and mitigate penalties.
  • Current Insights: How recent legislative and caselaw impacts penalty assessments and defences.

Expertise in Overturning CRA Assessments and Reassessments

Counter Tax Litigators LLP excels in helping clients navigate and overturn CRA assessments and reassessments that impose penalties. The firm's deep expertise in this area ensures that clients receive the most effective representation, resulting in superior outcomes.

"We're driven to provide our clients with superior results and clarity throughout the process. This commitment goes beyond mere words; we're genuinely dedicated to delivering optimal client results in every tax dispute," added Aprile.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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