This seminar focuses on selected types of transactions typically undertaken by corporations that have significant tax implications or are motivated by tax considerations. These transactions include corporate financing, reorganizations, remunerating owner-managers, and estate freezing. It is perfect for a Praxicum – a seminar combining theory, practice and reflection. Experienced and thoughtful practitioners will lead and participate in some discussions. It is taught with Mr. Nicholas McIsaac.
By focusing on the application of the General Anti-avoidance Rule (GAAR), this seminar supplement and enhance students’ learning of tax law materials in other courses in the JD program.
Expectations of students are similar to those of junior associates at a law firm or Department of Justice (DOJ): learning the materials with guidance and supervision; applying the knowledge gained from the readings for a specific purpose, e.g., identifying their “practical” implications for a client (a taxpayer or the CRA in the case of DOJ); critically reflecting upon the practical application in the context of the overall system design, purposes, and theoretical underpinnings of the Income Tax Act; and presenting the learning outcomes orally in class or writing (in the form of a memorandum).
To take this seminar, students should ideally have taken Taxation Law or are taking that course concurrently. Relevant corporate tax materials will be covered in this seminar so that students who have not taken the corporate tax course would be able to fully participate in the learning process. A detailed course outline and written guidance for each module of the class will be provided in advance.
It is very likely that the seminar will be taught on Zoom. Students are required to participate as if it is an in-person seminar.