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The in-depth course is definitely worth it, but its so expensive that it is for the best if you get into a firm that pays for it.

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8 hours ago, AnonLaw said:

The in-depth course is definitely worth it, but its so expensive that it is for the best if you get into a firm that pays for it.

Agree, it's hard to justify paying for it out of your own pocket. As mentioned, the CTF is the organization for tax professionals in Canada. 

 

In terms of the market, I think it's great for tax lawyers right now. Many tax lawyers I know are getting calls by headhunters, but primarily for planning, especially if you have a few years experience.

 

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11 hours ago, 1300vancouver said:

Thank you everyone for the replies.

I should have specified I am out of law school and presently articling. In law school I took tax and trusts, but mostly focussed on corporate law. 

It's only recently, through my articling experience, that I realized how much I love tax. 

Does anyone have experience with the job market for tax associates just finishing articles (should my firm not be hiring)?

I also was looking into the CPA In-Depth course. Is it worth it? 

Besides obtaining as much exposure to tax during articles as possible, is there any supplementary education/training etc that would make me a stronger candidate or perhaps showcase my genuine interest?

The good news is that I have heard of people hiring tax associates recently (at least in Toronto) - you might look into the captive law firms of the big 4 accounting firms.  

The two courses you will want to take are the CBA's "Tax Law for Lawyers" course and the CPA In-Depth courses.  Both are pretty expensive, so typically you get hired and you get your firm to pay for them.  The CBA course is excellent and is really a must have.  The In-depth course, meh, Part I and II are pretty much rehashes of stuff you'll have already done in law school - Part I is basically an introductory tax course for accountants - or (by the time you take them) in practice.  But you do deal with some issues that you probably don't deal with much in your practice.  I'd take the CPA course if someone else is paying for it.  

Beyond that, I think the key to demonstrating interest is get involved in the tax community, attend CTF young practitioner events (in Toronto they have regular sessions, and the odd reception, don't know about where you are), joining the CTF and bar association tax section, reading new cases, articles, etc.  

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More hopefully useful stuff for planning is:

1. Learn s.160 of the income tax act. Never taught in CPA tax courses, but its a very common assessment where lawyers get involved and very heavily litigated. You'll also want to get familiar with the GAAR.

2. Since you're in BC, learn the PST Act. It differs in some pretty big ways from the GST (all of them worse than the GST for the taxpayer). On that matter, start reviewing the Excise Tax Act (GST). GST is not taught in law school and the act itself is not the easiest to read if you don't know anything about it at the beginning.

3. Learn the family law act and the BC business corporations act. 

4. If you're doing planning it's time to start looking up non-profits and charities. Lots of planning work there.

5. Lots of tax planning opportunities involving aboriginal and cross-border matters. Lots of high dollar planning work there (but extremely technical)

I've seen some accountants and lawyers do some pretty magical stuff, like duplicating PUC or duplicating capital dividends. If CRA doesn't GAAR it within the reassessment period the client just got a gigantic windfall. Unless they revise the GAAR, but that doesn't seem to be on Ottawa's radar right now.

Also don't hang out your own shingle on tax planning. Litigation you can do if you put the time into getting to know the Rules and the Act, but planning requires a lot of precision and knowledge of the law. I don't do planning not because I don't know the rules but because I'd be afraid to mess something up and get sued. Planners often get extra liability insurance beyond the $1 million that we all get as lawyers, because one mistake that can't be fixed and you could go over that if you have very high dollar clients.

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On the PST point, the pool of GST/PST lawyers is very small. Most tax lawyers have zero interest in the area.   It takes some time to acquire practical knowledge, but it's not particularly hard (at a general level - specialized rules applicable to financial institutions are unintelligible) Even a modicum of knowledge in the area can make you very valuable to your firm.   When I was in private practice, I build up a small, but useful expertise on GST/PST law, so that I became the go-to guy for every person at the firm with a simple GST/HST and PST question. Even if you're not in BC, if you're at a firm with national clients or with offices in BC you should have a working familiarity with BC PST (and the PSTs in Sask and Man) so even if you can't advise clients, you can flag issues AND you become the go to person for client billing (since National firms with BC offices may have to charge and collect BC PST even if the work isn't done in BC - great way to get internal profile). 

I've considered offering to teach a GST course at UofT or Osgoode - it is a lacuna in their curriculum, given that gST/HST is relevant to every single lawyer coming out of law school (if only because they have to collect it on their bills). 

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9 minutes ago, maximumbob said:

On the PST point, the pool of GST/PST lawyers is very small.

Just on this topic and as a fun fact re: small pool, one individual in BC was responsible for crafting 99% of both the BC HST and the new BC PST (which was not a simple re-implementation of the old PST).

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4 minutes ago, kurrika said:

Just on this topic and as a fun fact re: small pool, one individual in BC was responsible for crafting 99% of both the BC HST and the new BC PST (which was not a simple re-implementation of the old PST).

That Bastard!!!!

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16 hours ago, maximumbob said:

The two courses you will want to take are the CBA's "Tax Law for Lawyers" course and the CPA In-Depth courses.

 Is the "Tax Law for Lawyers" a conference? Or did google show me something different 

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ITs a one week course, the CBA puts on in niagara on the lake (or maybe they’ve moved it to Niagara Falls).  They drag out a bunch of top practitioners to give seminars on specific core tax issues.  They probably call it a conference. 

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18 hours ago, maximumbob said:

On the PST point, the pool of GST/PST lawyers is very small. Most tax lawyers have zero interest in the area.   It takes some time to acquire practical knowledge, but it's not particularly hard (at a general level - specialized rules applicable to financial institutions are unintelligible) Even a modicum of knowledge in the area can make you very valuable to your firm.   When I was in private practice, I build up a small, but useful expertise on GST/PST law, so that I became the go-to guy for every person at the firm with a simple GST/HST and PST question. Even if you're not in BC, if you're at a firm with national clients or with offices in BC you should have a working familiarity with BC PST (and the PSTs in Sask and Man) so even if you can't advise clients, you can flag issues AND you become the go to person for client billing (since National firms with BC offices may have to charge and collect BC PST even if the work isn't done in BC - great way to get internal profile). 

I've considered offering to teach a GST course at UofT or Osgoode - it is a lacuna in their curriculum, given that gST/HST is relevant to every single lawyer coming out of law school (if only because they have to collect it on their bills). 

If you did it at Osgoode I would sign up! 

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Out of curiosity, between tax litigation and tax planning, which of the two currently has the better job prospects? 

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^ my uneducated (in that I haven't looked at job openings in a while) is that planning is the growth area.

 

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It probably depends. I mean, on the one hand, tax authorities are getting much more aggresive - more opportunities for tax Disputes. On the other hand, the ever more complicated laws mean more work on the planning side, just to comply with them. 

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There's also a lot of Boomers with extraordinary amounts of land wealth that are going to try and figure out how to keep as much of it as possible out of the hands of CRA.

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Are hours more stable and predictable in tax law (especially from the planning side)?

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16 minutes ago, Erebus said:

Are hours more stable and predictable in tax law (especially from the planning side)?

In theory, yes - generally tax lawyers are involved earlier in transactions so that things should be sorted out well before crunch time. And because people know tax is complicated, they tend to be more respectful when you tell them that this is going to take a while.  So, overall, yes - but note, more predictable and stable doesn't mean less.  But, it really depends on your practice and the nature of your clients.  I used to deal a lot with private placements of US offerings in Canada, where people would call you up on Friday because they wanted to do a trade on Monday and needed a wrapper with Canadian disclosure (that business has long since been shut down).  9 times out of 10 the tax analysis was brain dead, and you could fire it off in 30 minutes.  The other time, it was insanely complicated and ruined your weekend.  

 

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On 12/12/2017 at 10:04 AM, hORNS said:

Out of curiosity, between tax litigation and tax planning, which of the two currently has the better job prospects? 

FWIW, I get emails/calls from headhunters and they want planners probably 4 or 5 to 1 though I think that's because I'm in the 3-4 year range where that is a desirable amount of experience for a planner, less so for a litigator. I suspect it's about 5-7 for a litigator.

 

In terms of stable/predictable, I would say as a litigator generally yes, because I'm always litigating against the DOJ and they're reasonable and sane, and not jerks so I get a lot of control over my deadlines and while things never quite go as expected, generally I can see the peaks and valleys a ways away.

 

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1 hour ago, Chambertin said:

FWIW, I get emails/calls from headhunters and they want planners probably 4 or 5 to 1 though I think that's because I'm in the 3-4 year range where that is a desirable amount of experience for a planner, less so for a litigator. I suspect it's about 5-7 for a litigator.

 

In terms of stable/predictable, I would say as a litigator generally yes, because I'm always litigating against the DOJ and they're reasonable and sane, and not jerks so I get a lot of control over my deadlines and while things never quite go as expected, generally I can see the peaks and valleys a ways away.

 

YES - DOJ are generally reasonable and sane, and when they aren't, there's a good (and avoidable) reason. 

Private-side counsel are usually OK, but sometimes you get some bad apples. Particularly in family litigation.

Edited by AnonLaw

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