Upon completion of this course, participants will be able to:

• Identify and distinguish the primary sources of tax law (statutes, regulations, judicial decisions).
• Analyze the constitutional basis for a nation’s power to tax.
• Interpret complex tax legislation and apply it to specific fact patterns.
• Understand the role and hierarchy of administrative law (rulings, circulars, procedures).
• Explain the fundamental principles of statutory interpretation in a tax context.
• Describe the various stages of the tax appeals and judicial review process.
• Differentiate between tax avoidance, tax evasion, and tax planning.
• Understand basic legal concepts like jurisdiction, due process, and taxpayer rights.

• New Tax Auditors and Investigators
• Entry-Level Tax Professionals and Lawyers
• Paralegals and Legal Support Staff in Tax Departments
• Tax Policy Trainees and Researchers
• Compliance Officers in Financial Institutions
• Tax Administration Enforcement Staff
• Business Professionals seeking a legal tax foundation

• Hypothetical case analysis and legal memo writing exercises
• Moot court style oral arguments on tax law interpretation
• Group analysis of landmark tax court decisions
• Drafting and reviewing simple statutory provisions
• Discussion of ethical dilemmas in tax practice
• Workshops on navigating tax statute databases and legal research tools

Unit 1: Sources and Authority of Tax Law

• Sovereign power to tax and its constitutional limits
• Due process and equal protection in tax legislation
• Principles of separation of powers in tax matters
• Taxation and inter-jurisdictional commerce
• Tax legislation and the legislative process
• The role of referendums in fiscal decisions

• Primary tax statutes and enabling legislation
• Treasury regulations and administrative guidance
• Judicial precedents (case law) and their binding authority
• Tax treaties and international agreements
• Official rulings, circulars, and interpretative guidance

Unit 2: Principles of Statutory Interpretation

• Literal rule, golden rule, and mischief rule in tax law
• Purpose and context in statutory interpretation
• Canons of construction specific to tax law
• Dealing with ambiguities and contradictions in the tax code
• Interpreting "shall" vs. "may" and other key legislative language

• Understanding the court system and tax tribunals
• The doctrine of *stare decisis* (precedent) in tax cases
• Methods of distinguishing and overruling judicial decisions
• Role of superior and appellate courts in defining tax law

Unit 3: Legal Concepts in Tax Administration

• Right to appeal and dispute resolution mechanisms
• Confidentiality and disclosure rules for taxpayer information
• Concept of fairness and administrative justice
• The burden of proof in tax litigation
• Statutes of limitation for assessment and refund claims

• Defining tax planning, avoidance, and evasion (legal distinctions)
• General Anti-Avoidance Rules (GAAR) and their application
• Specific anti-abuse rules (SAAR) in various tax areas
• Criminal penalties and legal implications of tax fraud

Unit 4: Tax Treaties and International Law

• The relationship between domestic law and tax treaties
• Interpretation and application of the OECD and UN Model Conventions
• Treaty overriding and anti-treaty shopping provisions
• Mutual Agreement Procedure (MAP) and dispute resolution

Unit 5: Administrative Rulemaking and Procedure

• How tax regulations and rules are proposed, finalized, and challenged
• The binding effect of administrative rulings on taxpayers and the agency
• Procedural requirements for tax assessments and collection actions
• Legal aspects of information gathering (summons, exchange of information)