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CREDIT HOURS: 3

This course provides a detailed study of Canada's bilateral tax treaties. These treaties serve as a key part of Canada's international tax system. Their study should be of interest to students who are curious about taxation law and policy, to students with an interest in the international allocation of tax revenues between high and low income states, and to students who enjoy international law and politics. To provide a foundation for the study of specific treaty articles, we will review the underlying principles of international taxation and discuss approaches to tax treaty interpretation. The core of the course will involve a detailed review and evaluation of the design of the specific treaty articles, including the articles that govern business and professional income, employment income, the income earned by athletes and entertainers, real property income, and income from dividends, interest, royalties, and capital gains. The course also includes a discussion of the use of tax treaties in tax planning, the ways by which tax treaties are used as tools for tax avoidance, the mechanisms available in treaties to facilitate compliance, enforcement, and information collection, and the consequences of tax treaties for low-income countries.

Prerequisite(s): Taxation I (LAWS 2029). 
Co-requisite(s):Ìý±·´Ç²Ô±ð.
Assessment Method: This course is evaluated by major paper (and any other assignments or participation components as outlined in the course syllabus).
Restrictions:Ìý±·´Ç²Ô±ð.

*This course is unavailable to International Linkages students.