Peter Aprile

Popular Topics

Tax Accounting and Audit Corporate/Commercial Law Litigation, Mediation & Arbitration Finance and Banking

Peter Aprile’s articles from Counter Tax Litigators are most popular:

with Finance and Tax Executives and Inhouse Counsel
with readers working within the Accounting & Consultancy and Law Firm industries
within Litigation, Mediation & Arbitration, Corporate/Commercial Law and Strategy topic(s)
in North America and Canada

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www.countertax.ca

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AUTHORS CONTENT

Management's First Conversation With The Board In A CRA Dispute

When Institutional Continuity Becomes Management Exposure

Canada Strategy

How Courts Decide When A Transaction Can Be Read Two Ways

Canada Commercial

Loss Consolidation Under GAAR: When Interpretation And Judgement Decide The Outcome

When Corporate Losses Require More Than Mechanics

Canada Commercial

Control And Economic Reality In Cross-Border Dividend Disputes

Canada Litigation

CRA Reassessments Behave Like Capital Events

Costs Follow Control, Not Optimism

The Architecture Gap In Canada's Tax Dispute System

Canada Litigation

When CRA Scrutiny Shifts From Mechanics To Interpretive Requirements

CRA Audits And Disputes: A New Test Of Control And Judgement

Canada Accounting

Foreign Tax Interest Denied, Tax Court Loss Contained — Bank Of Montreal v. HMK

The Three Critical Inflection Points In CRA Challenges

Framing Gaps In SR&ED Disputes Shift Control To CRA

Transfer Pricing Disputes: How Forum Choice Alters Outcomes

The Standards That Enable Settlement In Tax Disputes

Mutual Fund Trust Disputes: When Form Without Execution Collapses

Surplus Cash And The Active Asset Test: Lessons From Ehresman

Strategic Deferral Of Departure Tax: Security, Liquidity, And Control

The CRA's TEBA Metric & March 31st Target: A System For Tax Disputes

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