This course helps students further develop statutory interpretation and problem solving skills through studying the international aspects of the Canadian Income Tax Act (ITA), tax treaties and recent global tax reform measures.
With a small open economy, Canada has developed an international tax system that is closely aligned with international norms but has features to reflect Canadian fiscal policies and Canadian interest in maximizing welfare for Canadians. The system has a clear paradigm, but many wonderfully complex rules to give effect to policy objectives. There is a fertile ground for international tax planning. This course will cover the paradigm, fundamental policies and basic technical rules.
A detailed Syllabus will guide students’ learning. Each segment of the course will contain practical problems to anchor the studying of the technical rules and related policies. A reader-friendly textbook that has been cited by the Supreme Court of Canada will be used as the main required readings. Problems, cases and professional commentaries will be used as supplementary materials. Students are expected to attend classes in person.