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William Byrnes (Texas A&M) tax & compliance articles

Archive for May, 2015

Several FIFA Executives Plead Guilty to Accepting Bribes, Many More Charged

Posted by William Byrnes on May 27, 2015


excerpt – The Defendants Include Two Current FIFA Vice Presidents and the Current and Former Presidents of the Confederation of North, Central American and Caribbean Association Football (CONCACAF); Seven Defendants Arrested Overseas; Guilty Pleas for Four Individual Defendants and Two Corporate Defendants Also Unsealed …

read full story at http://lawprofessors.typepad.com/intfinlaw/2015/05/fifa-officials-arrested-in-100-million-world-cup-bribery.html

Posted in Financial Crimes | Tagged: , , | 1 Comment »

Fulbright Awards and Fellowships for Law – Deadline August 3

Posted by William Byrnes on May 26, 2015

With over 80 Fulbright awards  available in countries around the globe for U.S. law professors, researchers and professionals, now is the time to refresh your thinking, and learn about law in a context other than that of the United States.  International Financial Law Prof Blog.

Posted in Courses, Education Theory | Leave a Comment »

Hiring Distance Education Director

Posted by William Byrnes on May 14, 2015

Texas A&M is seeking to hire a distance education full time position to execute upon and manage such programs.  Please refe Texas r any potentially interested distance education persons to the Texas A&M link:   https://jobpath.tamu.edu/postings/83039

Posted in Courses | Tagged: , , | Leave a Comment »

FinCEN releases new FBAR filing procedure !!!

Posted by William Byrnes on May 12, 2015

See the complete post at http://lawprofessors.typepad.com/intfinlaw/2015/05/fincen-provides-additional-e-filing-method-for-fbar-individual-filers.html

Posted in Uncategorized | Leave a Comment »

New Policy Restricts Use of Asset Forfeiture in Structuring Offenses

Posted by William Byrnes on May 7, 2015

justice logo

Under the new policy, in the absence of criminal charges, judicially authorized warrants to seize bank accounts involved in structuring can only be obtained if the prosecutor first develops probable cause of additional federal criminal activity and that determination is approved by a supervisor.  Otherwise, a prosecutor may ask a judge to issue a seizure warrant only if either the U.S. Attorney or the Chief of the Criminal Division’s Asset Forfeiture and Money Laundering Section personally determines that seizure would serve a compelling law enforcement interest.

In addition, the new policy imposes important protections after a seizure has taken place.  Read the full Attorney General’s Memorandum and the Structuring Policy Directive and story

Posted in Financial Crimes | Tagged: , , | Leave a Comment »

How Do Tax Rates Effect Innovation and Inventors ? Empirical evidence provides an answer!

Posted by William Byrnes on May 4, 2015


Posted in Uncategorized | Leave a Comment »

TJSL Ranks #13 in the Nation for Top Graduate Program | Thomas Jefferson School of Law

Posted by William Byrnes on May 1, 2015

TJSL Ranks #13 in the Nation for Top Graduate Program | Thomas Jefferson School of Law.

Posted in Courses | Tagged: , | Leave a Comment »

OECD Releases BEPS Proposed Action 8 on Cost Contribution Arrangements & Transfer Pricing

Posted by William Byrnes on May 1, 2015

Logooecd_enPublic comments are invited on a discussion draft which deals with work in relation to Action 8 of the Action Plan on Base Erosion and Profit Shifting (BEPS).

Action 8 (“Assure that transfer pricing outcomes are in line with value creation: Intangibles”) requires the development of “rules to prevent BEPS by moving intangibles among group members” and involves updating the guidance on cost contribution arrangements. The discussion draft sets out a proposed revision to Chapter VIII of the Transfer Pricing Guidelines and is intended to align the guidance in that chapter with the other elements of Action 8 already addressed in the Guidance on Transfer Pricing Aspects of Intangibles released in September 2014.

Interested parties are invited to submit written comments by 29 May 2015 (no extension will be granted) and should be sent by email to TransferPricing@oecd.org in both PDF and Word format. They should be addressed to Andrew Hickman, Head of Transfer Pricing Unit, Centre for Tax Policy and Administration.

Check out William Byrnes’ Lexis’ Practical Guide to U.S. Transfer Pricing, available within LexisNexis, which is updated Book Coverannually to help multinationals cope with the U.S. transfer pricing rules and procedures, taking into account the international norms established by the Organisation for Economic Co-operation and Development (OECD). It is also designed for use by tax administrators and tax professionals, corporate executives, and their non-tax advisors, both American and foreign.  Fifty co-authors contribute subject matter expertise on technical issues faced by tax and risk management counsel. Chapter 13 covers Cost Sharing Arrangements.

Posted in OECD, Transfer Pricing | Tagged: , , , | Leave a Comment »

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