This course provides students with an in-depth understanding of the international tax landscape, focusing on the interaction between the Canadian Income Tax Act and the global tax regime, in order to enhance their issue spotting and problem-solving skills when crafting international tax structures. The globalization of trade and investment flows as well as technological advances have created a borderless world which has profoundly affected income tax structuring for both individuals and Canadian corporations. Students will explore cross-border (USA) and offshore tax issues that are critical for Canadians engaged in global activities. The curriculum covers both domestic tax law and international tax rules and treaties, focusing on the various principles that are key for Offshore and Cross Border business structuring, such as Central Management and Control, Foreign Accrual Property Income (FAPI), Excessive interest and financing expenses limitation rules (EIFEL), the General Anti-Avoidance Rule (GAAR), revenue shifting and transfer pricing, the American Global Intangible Low Taxed Income rules (GILTI), international tax treaties, Organization for Economic Cooperation and Development (OECD) rules, Web3 and Metaverse related tax issues and more.
Method of Evaluation:
a) 70% exam
b) 30% Class participation and group projects/presentations