International Tax 101

This foundational module introduces CPA professionals to the statutory, conceptual, and jurisdictional framework of international taxation in Canada. It examines how Canadian tax law applies to cross-border transactions and taxpayers, focusing on the distinction between residents and non-residents under section 2 of the Income Tax Act (ITA) and the associated implications for worldwide versus Canadian-source taxation. Learners explore residency determination for individuals and corporations, sourcing rules, withholding tax regimes, and the reporting landscape, including compliance with Forms T1135 and T1134. The module also explains the legal meaning of carrying on business in Canada, the role of permanent establishments under domestic law and tax treaties, and introductory anti-avoidance provisions such as GAAR, thin capitalization rules, and the transfer pricing framework. Through case-based application and real-world examples, professionals will gain the necessary awareness to identify international tax issues early, apply dual residency and treaty tie-breaker tests, and prepare clients for increasingly complex cross-border reporting and compliance obligations.