William Byrnes' Tax, Wealth, and Risk Intelligence

Last chance to join one of the case study teams for TRANSFER PRICING taught live online, using Zoom, by Dr. Lorraine Eden, Prof. William Byrnes, and many industry experts… The courses are for tax attorneys, accountants, or economists and count toward the Texas A&M’s INTERNATIONAL TAX Master degree (taught online).

The class of a maximum of 18 students will be grouped into teams of 3 students each. The 6 teams meet using Zoom to prepare a weekly presentation to respond to a real-world post-BEPS client study. Then all teams meet together online via Zoom twice each week at 8:00am Dallas time Wednesdays and Sundays to discuss and present the case study solutions. Students are provided without charge textbook materials, videos with PPT, and podcasts, and granted access to a large online law & business database library including Lexis, Bloomberg, IBFD, Kluwer/CCH, Thomson, among many other tax resources.

To apply for the transfer pricing courses and international tax courses, contact Jeff Green, Graduate Programs Coordinator, T: +1 (817) 212-3866, E: jeffgreen@law.tamu.edu or contact David Dye, Assistant Dean of Graduate Programs, T (817) 212-3954, E: ddye@law.tamu.edu. Texas A&M Admissions website: https://law.tamu.edu/distance-education/international-tax  (applications and previous university transcripts must be received by Admissions before Wednesday, January 8th at 5pm Texas time). Note that the university is closed for the holidays from Dec. 20 until Jan. 2, 2020.

• Strength of the Aggie Network: Texas A&M, annual budget over $6 billion (FY2020), is the second-largest U.S. public university, with the renown Aggie former students network exceeding 500,000 around the world, Texas A&M is 1 of only 60 accredited U.S. universities of the American Association of Universities (R1: Doctoral Universities – Highest Research Activity) and 1 of only 17 U.S. universities that hold the triple U.S. federal grant of Land, Sea, and Space!
• #1 endowment for U.S. public universities, #7 overall
• #1 of U.S. public universities for a superior education at an affordable cost
• #1 for most CEOs employed by Fortune 500

Course I: Tangibles, Methods

• Week 1 January 13 Arm’s Length Standard (v Formulary Approach) case study
• Week 2 Jan 20 CUP & Comparables case study
• Week 3 Jan 27 Cost Plus & Resale Minus case study
• Week 4 Feb 3: Comparable Profits Method & TNMM case study
• Week 5 Feb 10 Profit Split case study
• Week 6 Feb 17 Best Method case study

Course II: Intangibles, Services

• Week 1 March 2 Intangibles Royalty Rates CUT and CPM case study
• Week 2 March 16: CSA Intangibles Buy In/Out case study
• Week 3 March 23: Digital Business Unitary Apportionment case study
• Week 4 March 30 Digital Value Chain, Internet of Things case study
• Week 5 April 6 U.S. v OECD v UN Manual case study Extractive Industries, Financing
• Week 6 April 13 Restructuring the Business, Services case study