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

Archive for July, 2016

Texas A&M Soars to #4 for Public University Rankings

Posted by William Byrnes on July 25, 2016

The 2016 rankings have been released and Texas A&M University has soared to rank #4 money-logoamong all public universities in Money magazine’s new “Best Colleges For Your Money” report.

The top five ranked public universties in the USA are:

#1 University of Michigan

#2 University of California, Berkeley

# 3 University of Virginia

#4 Texas A&M University

#5 University of California, San Diego

Moreover, Money reported that Texas A&M University ranked #3 for number of Fortune 500 CEOs.  #1 Harvard, #2 Cornell and #3 Texas A&M University.

For this year’s “Best Colleges For Your Money” list, Money ranked 705 schools on 24 factors. Rating factors included graduation rates, alumni success, how much recent graduates earn, cost of education, and it began to incorporate data from the federal government’s College Scorecard.

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Framework for Transfer Pricing Analysis Under Treasury Regulation Section 1.482 and the OECD Guidelines

Posted by William Byrnes on July 12, 2016

This chapter from Practical Guide to U.S. Transfer Pricing, available from SSRN here,  compares the U.S. Section 482 transfer pricing regulations to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as revised in 2010.

Section 482’s purpose is to ensure that taxpayers subject to U.S. taxation “clearly reflect income” related to transactions with other organizations that are under common ownership or control with the taxpayer, and “to prevent the avoidance of taxes with respect to such transactions.” The desired result is “tax parity” between the “controlled taxpayer” and an “uncontrolled taxpayer,” and, thereby, to determine the “true taxable income” of the controlled taxpayer. Similarly, the 2010 Guidelines state that the arm’s length standard which flows from recognizing the separate entity status of related entities in different jurisdictions has the dual objective of securing an appropriate tax base in each jurisdiction and avoiding double taxation.

Since many U.S. trading partners follow the OECD Guidelines (and to a certain extent the Book CoverUnited States also does) similarities and differences between the OECD Guidelines and the U.S. regulations are important.

Number of Pages in PDF File: 93

Framework for Transfer Pricing Analysis Under Treasury Regulation Section 1.482 and the OECD Guidelines (July 5, 2016). William Byrnes & Robert Cole (deceased), Practical Guide to U.S. Transfer Pricing § 2.01 – § 2.19 (Matthew Bender, Third Edition). Available at SSRN: http://ssrn.com/abstract=2805279

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Texas A&M Law Partners With BarBri, Reduces Tuition by 15% and Increases Scholarships by 65%

Posted by William Byrnes on July 11, 2016

Texas A&M University School of Law is pleased to announce a partnership with the BARBRI Group that provides all1ee6c-6a00d8341bfae553ef01b7c80b4769970b-320wi incoming first-year Aggie law students the post-graduation BARBRI Bar Review course, as well as BARBRI law school materials, bar prep apps and programs while in law school.  This partnership announcement comes on the heels of Texas A&M University announcing a 15.39% reduction in the public law school’s tuition, that a student’s tuition rate will remain locked-in for the three-year education,  and that the university has increased the scholarship awards budget by 65% to attract the brightest candidates.

At Texas A&M Law, our commitment to student success starts with building a strong foundation of knowledge from the beginning of the law school experience. While law school is of course about much more than just passing the bar exam, to become the exceptional Aggie lawyers we prepare our students to be, they must first pass the bar exam.

Please watch the announcement below with Professor James McGrath, director of Academic Support and Bar Services, and Mike Sims ’87, president and CEO of BARBRI, to learn more:

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headlines from Financial Law Prof Blog – July 8

Posted by William Byrnes on July 8, 2016

Will UK Be Branded a Tax Haven by OECD and EU To Punish It for Brexit

INtelligence wheel all agencies

Financial Law Prof Blog

Turkey to grant tax-free amnesty for Turkish residents’ assets abroad

Canada Updates Money Laundering and Terrorist Financing Act, 2016

Taxpayer Advocate Mid-Year Report to Congress: IRS Implementation and Enforcement of FATCA Withholding Is Burdensome, Error-Ridden, and Fails to Protect the Taxpayers’ Rights

OECD releases revised guidance on profit splits

OECD Release of BEPS discussion draft on attribution of profits to permanent establishments

Protecting Older Americans from Financial Exploitation

Film fraudsters jailed for 27 years in £100 million tax avoidance scam

The Economic Impact of U.S. Innovation

Outcomes of the Plenary meeting of the FATF 22–24 June 2016

Chinese National Sentenced to 30 Months in Prison for Smuggling High Tech U.S. Military Hardware to China

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