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

Canadian lawyers frequently confront tax issues that have a cross-border component.  This course provides an introduction to the US Internal Revenue Code (the federal tax statute), giving students experience reading and parsing the statutory language, especially when different code sections interact.  The course also explains how taxpayers can challenge the government’s enforcement of the Code, as well as how administrative decisionmakers and the courts choose from among various available methods of statutory interpretation.  Specific exercises will provide practice in working with the Code, while judicial opinions and official administrative guidance will explicate the interaction between taxpayers, practitioners, the federal government, and the courts.  Most of the substantive issues will derive from the income tax (both personal and business), although wealth taxes or other parts of the Code can become relevant at various points.  Issues will include how income is defined, how taxes can be delayed and reduced, how tax rates are determined and applied, and the US tax treatment of taxes paid in Canada.