We consider panel parametric, semiparametric and nonparametric methods of constructing counterfactuals. We show through extensive simulations that no method is able to dominate other methods in all circumstances, since the true data-generating process is typically unknown. We therefore also suggest a model-averaging method as a robust method to generate counterfactuals. As an illustration of the sensitivity of counterfactual construction, we reexamine the impact of California's Tobacco Control Program on per capita cigarette consumption and election day registration (EDR) laws on voters' turnout by different methods.