603 International Taxation (Woltersdorf)

LAW603

International Taxation

(Woltersdorf)

Prerequisite courses: LAW504 Taxation

Prerequisite for:

Instructor(s): Mark H. Woltersdorf, FCPA, LL.B.

Course credit: 3

Method of presentation: Lecture

METHOD OF EVALUATION

100% final exam.  Examination is OPEN BOOK.

COURSE DESCRIPTION

International taxation involves issues concerning taxation of transactions where more than one jurisdiction is involved.  Canadian taxpayers are engaging in foreign and cross-border transactions with increasing frequency as a consequence of free-trade agreements, online access to goods, services and information and global competitiveness.  

The course begins with an overview of the OECD’s Base Erosion Profit Shifting project (BEPS), the multi-lateral instrument (MLI) and Canada’s response to Pillar 1 and 2, followed by a study of Canada’s network of tax treaties and the principles of tax treaty interpretation.  Following this overview the emphasis shifts to core topics including the concepts of residence and non-residence for tax purposes; the taxation of non-residents of Canada who are employed in Canada, carry on business in Canada or dispose of taxable Canadian property; the taxation of non-residents of Canada who derive income from investment or other passive income sources in Canada, the taxation of Canadian residents who derive income from foreign sources; the taxation of foreign affiliates; the use or misuse of tax havens; international tax planning; transfer pricing; and methods to counter international tax evasion. 

SPECIAL COMMENTS

Description updated 2023-2024. Please contact the instructor for any specific questions you may have related to this particular course section.

REQUIRED TEXTS

Introduction to International Taxation in Canada – current ed., Vidal

Current copy of Income Tax Act