This course offers a foundational understanding of the international dimensions of the Canadian Income Tax Act, tax treaties, and recent global reform initiatives. It focuses on how legal rules govern cross-border income and how globalization affects the structure and application of those rules, particularly for Canadian taxpayers engaged in international activities. Topics include jurisdiction to tax, non-resident taxation, outbound investment, the foreign affiliate regime, foreign tax credits, and transfer pricing. The course also addresses developments from OECD and G20 initiatives, with attention to their implementation in Canadian law and interaction with tax treaties. Students will interpret relevant provisions and apply them through case studies and illustrative fact patterns, building familiarity with the technical operation of international tax rules and the statutory frameworks that support them.
This course offers a foundational understanding of the international dimensions of the Canadian Income Tax Act, tax treaties, and recent global reform initiatives. It focuses on how legal rules govern cross-border income and how globalization affects the structure and application of those rules, particularly for Canadian taxpayers engaged in international activities. Topics include jurisdiction to tax, non-resident taxation, outbound investment, the foreign affiliate regime, foreign tax credits, and transfer pricing. The course also addresses developments from OECD and G20 initiatives, with attention to their implementation in Canadian law and interaction with tax treaties. Students will interpret relevant provisions and apply them through case studies and illustrative fact patterns, building familiarity with the technical operation of international tax rules and the statutory frameworks that support them.
