International Tax II

In today's business environment Canadian companies are rapidly expanding and competing in the global marketplace. Given the existing level and the continual expansion of cross-border trade and investment by Canadian companies, particularly in the age of electronic commerce, an understanding of international taxation is vital for every tax practitioner and business advisor. International Tax II builds on the fundamental principles taught in International Tax I. The course examines in more detail the foreign affiliate and foreign accrual property income rules and practices that apply to Canadian companies seeking to establish, expand, structure and finance their foreign operations in a tax efficient manner. The course challenges students to explore the implications and planning opportunities under the Canadian rules and to learn how these rules interact with foreign tax law. The course also examines how Canadian companies can make effective use of low-tax jurisdictions in international tax planning to own and to finance foreign operations. Finally, the course explores how domestic and international developments and rules, such as transfer pricing, might impact such planning currently and in the future.