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Tax Student's Research Grabs International Attention

By John Masson
May 16, 2013

International Tax LLM student Amir Pichhadze, still adjusting to the fact that his paper in Tax Notes International is currently the fourth-most-downloaded among tax practitioners, also needs to consider this: he'll be presenting that paper soon at one of Canada's most-prestigious gatherings of experts, the Commodity Tax Symposium in Ottawa.Amir Pichhadze

Pichhadze, graduated Michigan Law with his LLM in International Tax this month and who is applying to continue studying tax at Michigan as an SJD student in the fall, is trying to take the success of his article in stride. The paper, "Input Tax Credits: What Canada's Federal Court of Appeal Could Have Learned From the U.K. VAT," already has generated gratifying positive feedback from practitioners, mostly in Canada, he said.

The case behind the paper—CIBC World Markets v. R.—posed a novel question under Canada's consumption tax, known as the GST: can a GST registrant change its method of calculations retroactively, for the purpose of calculating its Input Tax Credits?

The question may seem arcane, Pichhadze said, but what actually happened as the case worked its way through the Canadian justice system was not. Because there weren't applicable precedents in Canada, the trial court judge sought guidance from the jurisprudence surrounding Britain's Value Added Tax, which is similar to Canada's GST. But on appeal the Federal Court of Appeal decided the lower court shouldn't have used British precedent, even as a guide, in the Canadian case, because the GST system is "somewhat different" from the British VAT.

Thus, Pichhadze said, another possible case of fruitful "judicial globalization" or cross-fertilization was stymied. He became intrigued. He was already well-grounded in Britain's VAT law, having studied it while earning an LLB and LLM at the London School of Economics. And he'd just completed a clerkship at the Tax Court of Canada. So he began researching the topic.

He argues that properly researched foreign law should have had a place in the case, because the VAT and the GST—like most such taxes—share a common legal underpinning. Now he finds himself preparing to present his findings to an audience of Canada's most influential tax experts at the Commodity Tax Symposium in the country's capital from Sept. 30-Oct. 1.

Pichhadze, whose father is a noted visual artist and gallery owner, emigrated to Canada from Israel when he was 12 years old. Pichhadze initially followed the same course, becoming a noted artist himself, but eventually gravitated toward the law as something more intellectually stimulating. He said he knew international tax was something he wanted to learn more about as soon as he completed his clerkship at the Tax Court of Canada.

"When I was looking at schools, everyone—and I mean, everyone—told me to pursue studying with Prof. Avi-Yonah at Michigan," Pichhadze said. "His was the only name that came up."

In addition to the advanced opportunities for international tax scholarship Pichhadze found here, he has found something else, as well: a student spirit in Ann Arbor that's unlike anything he's encountered before.

Having grown up largely in the cosmopolitan bustle of Toronto and after spending four years studying in London, Pichhadze said he can't think of anywhere he'd rather be a student than Ann Arbor.

"I found campus life to be wonderful," Pichhadze said. "I think Ann Arbor is a wonderful city to live in, a good mix in a laid-back environment with a fantastic student body. It's energetic, but it's more than that. It's the University's spirit."

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