University of Calgary

A series of tax law tutorials prepared by Professor Catherine Brown 
Faculty of Law, University of Calgary 
brownc@ucalgary.ca

Updated in 2021.

This course provides students with the opportunity to study tax law in a global context. It covers both domestic tax law and tax treaties. Specific issues include jurisdiction to tax, non
-residents earning income in Canada; cross-
border services; Canadians earning income offshore; the foreign tax credit, the foreign
affiliate system, international tax avoidance and
transfer pricing. This course is designed to help students develop an understanding of
international tax law as well as to understand the framework underlying international tax planning. It will also provide students with an appreciation of the major impact that the
globalization of trade and investment flows is having on the practices and policies of income taxation.

Welcome to Basic Tax. I look forward to our adventure together. I suspect many of you will not practice in the tax area. What I hope we can achieve in this course is to familiarize you with basic tax concepts and with how tax issues will affect other areas of legal practice. And for those of you who do want to practice in the tax area the goal is to provide you with a solid grounding in tax principles and practice.
The course will combine pre-recorded lectures, instructor-lead lectures and in-class group discussion problems.
The course is designed to introduce you to Canadian income tax law as it applies to the taxation of corporations and shareholders. The course discusses the classification of corporations for tax purposes, the rules applicable to the taxation of corporate income including the taxation of active business income, investment income and corporate distributions, the rules applicable on the transfer of property to a corporation, to various types of corporate reorganizations and to the winding up of a corporation. The course focuses on privately held corporations and their shareholders and addresses such issues as owner-manager remuneration, corporate rollovers and anti-avoidance provisions.
Estate Planning involves the application of the laws relating to wills, trusts, personal and
real property, insurance, conflict of laws, corporate law and income tax, among others, to
a particular individual’s assets. Its goal is to enable that individual during his or her
lifetime to best utilize their assets and on death to dispose of any remaining property to
the designated heirs with the minimum tax liability.
The scope of this course precludes a review of all the laws pertaining to estate planning.
Its focus will be primarily on the tax aspects. However, other areas of estate planning will
be highlighted including important tax planning issues in drafting wills, trusts and
shareholder and partnership agreements.
The topics to be discussed include: taxation of the deceased taxpayer, taxation of the
deceased’s estate and beneficiaries, taxation of trusts, tax roll-overs, the capital gains
deduction, will and post mortem planning and selected estate planning topics such as tax
planning for persons with disabilities, second marriages, business succession and foreign
beneficiaries. The materials to be discussed are directed towards planning for a wide
range of clients. The seminar is designed to be a joint learning experience. Each student
will be expected to be prepared for all session