US Taxation of Individuals and Businesses

Canadian lawyers frequently confront tax issues that have a cross-border component.  This course introduces students to the Internal Revenue Code (the federal tax statute in the United States), giving students experience reading and parsing the Code’s statutory language and studying competing methods of interpretation.   

This course is designed primarily for (1) students who wish to practice law in Canada, particularly tax or corporate law, and (2) for students who will practice law in the United States, particularly tax or corporate law.  The course will be an in-depth study of the United States’ tax Internal Revenue Code as it applies to individuals, corporations, and business transactions (e.g. mergers and acquisitions).  Although some policy will be discussed, most of the course will deal with substantive law such that students can learn all necessary ingredients to engage in sophisticated tax work, whether cross-border or in the United States.  Substantively, this course will focus on rules applicable to business corporations in the United States and related rules regarding acquisitions, mergers, and dispositions, and the important rules relating to individual taxation that are seen often in practice, such as the rules relating to debt instruments, dividend taxation, capital gains, employment income, and more.