International Taxation: US Tax Law for Canadian Lawyers (LAW354H1S)

Canadian lawyers frequently confront tax issues that have a cross-border component.  This course introduces students to the Internal Revenue Code (the federal tax statute in the United States), giving students experience reading and parsing the Code’s statutory language and studying competing methods of interpretation.  The course explains how taxpayers can challenge the government’s enforcement of the Code and how administrative decisionmakers and the courts choose from among various available methods to resolve tax disputes.  We will work through examples of tax problems, and we will study judicial opinions and official administrative guidance along with the Code itself.  Most of the substantive issues in the course are based on the income tax (both personal and business), although wealth taxes or other parts of the Code occasionally become relevant.  The course will address how income is defined, how taxes can be delayed and reduced, and how tax rates are determined and applied.