The CICA's International Tax Courses
The CICA's Advanced International Tax (AIT) course has been split into two courses--one that was offered for the first time last year, and a second that is still on the drawing board. The coverage of international tax in the CICA's In-Depth Tax Course is unchanged.
Enrolment in the AIT course had declined from 80 participants in 2006 to 40 in 2009. The AIT course was primarily an advanced "foreign affiliate rules" course geared toward international tax specialists with several years of experience in the field. For example, the AIT course timetable included advanced coverage of such topics as transfers and reorganizations of foreign affiliates, outbound structuring and financing, and the foreign accrual property income (FAPI) regime.
According to the report of the CICA's Tax Education Task Force (cpd.cica.ca/TaskForceReport_2012.pdf), one cause of the decline in enrolment may have been an increasing number of younger practitioners joining the tax practice as a result of the waiver of the audit-hours requirement for the CA designation. Many course participants had less than three years' experience in international tax or were non-specialists who did not intend to pursue a career with a strict focus on international tax matters. Participants from industry indicated that the AIT course was too specialized for their purposes. For all these reasons, the course was redesigned. The new Foundations of International Tax (FIT) course was offered for the first time in the fall of 2011 to more than 90 participants, 35 percent of whom had a background in industry.
The four-day FIT course is designed to be part 1 of a two-part international tax curriculum, and is intended to provide broad-based coverage of both inbound and outbound international tax rules. The FIT course will be of interest to practitioners who are beginning their international tax practices, and to non-international tax specialists who want to increase their knowledge base for the purpose of issue identification. The topics covered in last year's sessions included relief from double taxation, basic treaty concepts, an introduction to cross-border personal taxation, transfer pricing, and US international tax concepts. More sophisticated topics such as FAPI, the foreign affiliate surplus rules, and the financing of foreign affiliates were also covered, though at a more introductory level.
The FIT curriculum will undergo further refinement for the November 2012 offering, with enhanced coverage of the foreign affiliate reorganization provisions (albeit still at a relatively introductory level) and an increased focus on the Canada-US tax treaty.
Part 2 of the revised international tax curriculum has yet to be finalized, and may be offered for the first time in 2013. The focus of the course is expected to be on advanced issues in foreign affiliate reorganizations; however, there will also be in-depth coverage of treaty issues, including the Canada-US tax treaty, as well as advanced outbound and inbound financing issues. The delivery mechanism is still under discussion. For example, the CICA is considering whether splitting the course into shorter sessions and moving away from the traditional in-residence format would make for a better learning environment. For more information, write to Vivian Leung of the CICA (firstname.lastname@example.org).
Deloitte & Touche LLP, Ottawa
Editor's note: The May 2012 Canadian Tax Focus article on the changes in the In-Depth Tax Course triggered online comments relating to whether the CICA plans to offer a tax specialization. The CICA is assessing all of its specialization programs, and expects to have more information available in the fall.