We sat down with Angela I. Salvatore, an alumna of Osgoode’s Full-Time Professional LLM in Tax Law, to find out more about her, why she undertook the LLM, what she gained from it, and what others should know.
We kicked off with a discussion of who Angela is (a constant learner and problem-solver!) and her love for tax. To her, education is primary – it’s everything – and tax lends itself to those who have an academic bent because it is such a technical and complex area of law.
As for the problem solving, well that comes naturally (Tax lawyers like to take things apart and put them back together. That’s the heart of what we do as lawyers – we’re supposed to be problem-solvers, not obstructionists!). Let’s see how these attributes influenced her decision to pursue the LLM.
What was your motivation for undertaking the LLM?
When I was doing my JD at Osgoode Hall, I enjoyed the tax courses I took. I was a RA for professor Lisa Philipps in my third year. I loved the area and wanted to immerse myself in it.
For me, there is no other area of law that one can practice in on a daily basis that resembles the law school experience. The area itself is so specific that you could spend hours looking at a specific subsection of the Income Tax Act, Excise Tax Act, or tax treaty! I always knew I’d do the LLM. It was just a matter of timing.
Can you describe your experience in the LLM?
Osgoode’s LLM is the longest running and most prestigious LLM in Tax in the country. It was an amazing experience.
I couldn’t have asked for a better faculty. I loved the experience and the intellectualism of it all. The classes were small enough that we could discuss cases and legislation. You felt comfortable enough to do that.
I was worried about how I would be perceived going in given that I had a previous career in another area of law and how I would make out, but those fears were dispensed within my very first course. My prof made it so that everybody could contribute – it didn’t matter that I came to tax via a non-linear / non-traditional path. I could dispense with the concern and participate with ease.
I met so many people that I continue to keep up with, as far away as British Columbia. Tax lawyers and accountants, I try to have monthly calls with one of them – we talk about everything. The LLM broadened my network considerably. Then, there’s the knowledge and the materials; I go back and reference them all the time.
What was the dynamic like between lawyers and non-legal professionals?
There was no difference. That was surprising to me. I often wondered how difficult it would be for the non-legal professionals to join an LLM program at law school.
The accountants I encountered were quite knowledgeable. They had the technical aspects down; they were just there to delve into the legal aspects. There was a great deal of collaboration. Oftentimes, we would stop and discuss certain things and do presentations. The collaborative nature between the two groups worked well.
How have you applied what you learned?
If I have someone that comes in with a treaty issue, I’ll go back to my course with Prof. Kim Brooks on Treaties. I’ll pull it up.
There isn’t a week that goes by that I’m not pulling up my notes, a text, or an article that was provided during the course. I’m always pulling up the Fundamentals of Canadian Income Tax. It’s constant. Sometimes, I’m not even sure if we covered a particular tax concept and I’ll bet that we did, and we did. Sometimes, I review the PowerPoint slides provided. It makes the research that much easier. It also helps to confirm that I’m on the right track.
You returned for single LLM courses. What led you to do so?
I went back right away. Because there were so many Single Course Enrollment courses offered, there were times I was doing two courses [at once]. I wanted to ensure that I had all of the tax knowledge and took all of the tax courses that were available.
There’s a momentum that builds. You get into a mode of reading and writing, and I was able to sharpen those skills. I was able to do that in a way I never imagined because I wrote so much within the academic area. Researching, budgeting time, and honing in on what you need to look for and draft… there’s something that can be said of the impact that has on your ability to practice and do things efficiently in ways that someone who hasn’t taken an LLM couldn’t.
In order to continue [taking as many courses as I could], I began an LLM in General Law afterward. All in all, I took 16 tax courses, wrote 16 final tax papers. I earned half of the credits required towards a second LLM degree.
If you could share anything with prospective Tax Law students, what would it be?
Be persistent and know that an LLM in Tax Law will set you apart from your colleagues. It will be looked upon with great interest. People will sit up and take notice. People need to know that.
And not just within Canada! It comes highly regarded by the top-tier law schools that offer LLMs in Tax even in the United States. I’ve had the opportunity to speak with lawyers from NYU and Georgetown, UCI, and the University of Florida. They’ve commented on how highly regarded Osgoode’s LLM in Tax program is and that Osgoode is known for Tax. I’ve even known people within Canada who attend Osgoode when they could attend law schools in their own provinces that offer LLMs in Tax.
And finally, you have an event coming up! Tell us more.
Yes! We are running a Women in Tax Program, a joint program between the OBA Women Lawyers’ Forum and the Taxation Law Section, at which I am a speaker. Some of the topical areas include how to break into the area of tax law, keys to professional growth, overcoming challenges within the tax law community, and strategies on how to excel.
This is an important program for me as I am currently the first female Chair of the OBA Taxation Law Section.
— CBA Women Lawyers (@CBA_WLF) April 5, 2021
Readers may learn more and register, here: https://www.cbapd.org/details_en.aspx?id=on_on21tax04i&_ga=2.138508404.615692525.1617810872-1455067141.1587041134
Angela I. Salvatore BA, JD, LLM (Taxation), is a Tax Planning, Dispute Resolution, and Litigation Lawyer in Toronto. She came to tax via unconventional means, with a previous career in the non-tax area, early in her legal career, prior to her permanent transition. The attraction to tax law commenced in the JD program at Osgoode Hall Law School and was solidified in her capacity as a RA in her last year of law school for a tax law professor. Angela is currently the Chair of the OBA Taxation Law Section – the first female to hold the position. At present, she is dually studying for her first Society of Trust and Estate Practitioners’ Canada exam in May of this year towards her Trust and Estate Practitioner designation and for the New York State bar. Also, Angela is taking French lessons with the aim of becoming fully bilingual and able to represent taxpayers before the Tax Court of Canada in both official languages.