William Byrnes' Tax, Wealth, and Risk Intelligence

Want to join one of the case study teams for the international tax risk management courses taught live online, using Zoom, by industry’s recognized tax risk leaders and leading tax authors?  The courses are for tax attorneys, accountants, or economists and count toward the Texas A&M’s Master and LL.M. degrees in residence and 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 twice together each week ‘in live session class’ via Zoom with the industry case study topic expert professor and the course professor, 9:00am – 10:30am Dallas Central time to discuss and present the case study solutions. Students are provided without charge the learning and textbook materials, videos with PPT, and podcasts, and granted access to a large online law & business/tax database library including Lexis, Bloomberg, IBFD, Kluwer/CCH, Thomson, BvD, S&P, among many other tax and financial data resources.

To apply for the 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 require university transcripts delivered by May 15).

Strength of the Aggie Network: Texas A&M, annual budget over $6 billion (FY2020), is the 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

SUMMER 2020 (May 18 through June 30)

FATCA, CRS, AEoI, Systems and Data: 3 credits (meet Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Week 1. May 18: FATCA, CRS, and EU: nationality, residency, data sharing: Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU).

Week 2. May 25: FATCA/CRS and the Asset Management Industry, intermediaries: Denise Hintzke (Deloitte)

Week 3. June 1: FATCA Withholding Compliance, overlap with QI: Denise Hintzke (Deloitte)

Week 4. June 8: Documentation FATCA v CRS: Danielle Nishida (KPMG) / Laurie Hatten-Boyd (KPMG)

Week 5. June 15: Danielle Nishida (KPMG) or Laurie Hatten-Boyd (KPMG)

Week 6. June 23: Financial Institutions Systems And Data: Haydon Perryman (Bank of America, UBS, Barclays, RBS and Lloyds) 

International Tax Risk Management I (Data, Analytics & Technology) 3 credits (meet Tuesday and Friday at 9am Central Daylight Dallas time zone)

Week 1. May 18: BEPS: Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU).

Week 2. May 25: Interest (thin cap, EBIDTA):

Week 3. June 1: CbCR & Analytics David Deputy, Vertex

Week 4. June 8: LOB / PPT / MLI: Dr. Bruno da Silva (Loyens & Loeff)

Week 5. June 15: General tax risk management approach Dr. Knut Olsen

Week 6. June 23: Future of Analytics & Technology from a Risk Management Perspective: Dr. Paula de Witte 

FALL 2020 (Aug 23 through Nov 23) 3 credits (meet Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Domestic Tax Systems Risk Management

Week 1 Aug 23 Canada (extractive)

Week 2 Aug 30 Mexico (manufacturing)

Week 3 Sept 6 India (services)

Week 4 Sept 13 China (supply chain)

Week 5 Sept 20 Japan Dr. Maji Rhee (Waseda) (comps and secret comps)

Week 6 Sept 27 UK (financial services) 

International Tax Risk Management II (Data, Analytics & Technology) 3 credits (meet Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Week 1 Oct 11 Technology industry (Dell) Pillar 2 – CFC, GILTI, related

Week 2 Oct 18 Manufacture

Week 3 Oct 25 Oil & Gas

Week 4 Nov 1 Tax of Patents / Technology, Dr. Brigitte Muehlmann (Daylight time ends, Wednesday and Sunday at 8am Central Standard Dallas time zone)

Week 5 Nov 8 Tax Risk & Tax Technology, Dr. Brigitte Muehlmann

Week 6 Nov 15 Tax Risk & Tax Technology, Dr. Brigitte Muehlmann   

International Tax & Tax Treaties I: Residency Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Week 1 Aug 23 Domestic Tax Rights; Double Taxation; Tax Treaty Allocation Of Tax Rights

Week 2 Aug 30 Types Of Taxes; Tax Treaty Interpretation

Week 3: Sept 6 Tax Jurisdiction Over Persons, Tax Treaty Interpretation

Week 4: Sept 13 Tax Jurisdiction of Corporations; Tax Treaty Interpretation & Application

Week 5: Sept 20 Tax Jurisdiction of Entities

Week 6: Sept 27 Pillar 1 And 2 (Taxation of Digital; Min Effective Tax)

 International Tax & Tax Treaties II: Source Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Week 1 Oct 11 Tax of Business Income

Week 2 Oct 18 Tax of Investment Income

Week 3: Oct 25 Taxation of Services and Employment Income

Week 4: Nov 1 Double Taxation and Tax Credits (Daylight time ends, Wednesday and Sunday at 8am Central Standard Dallas time zone)

Week 5: Nov 8 Tax Accounting

Week 6: Nov 15 Introduction to Management of Tax and Data

Capstone Nov 23: Groups Create Client Case Studies

SPRING 2021 (Jan 10 – April 26)

U.S. Tax Risk Management (Data, Analytics & Technology) 3 credits (Wednesday and Sunday at 8am Central Standard Dallas time zone)

Week 1 January 10, 2021 Outbound / FDII Melissa Muhammad

Week 2 January 17, 2021 Inbound / BEAT Melissa Muhammad

Week 3 January 24, 2021 [check the box] Form 1120 Documentation: Neelu Mehrotra: EY

Week 4 January 31, 2021 [Subpart F & GILTI, PTEP ] Form 5471 Documentation: Neelu Mehrotra: EY

Week 5 February 7, 2021 M&A or topic and Neelu Mehrotra: EY

Week 6 February 14, 2021 FTCs; wrap-up: Melissa Muhammad 

E.U. International Risk Management 3 credits (Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Week 1 February 28, 2021 General Framework & Fundamental Freedoms

Week 2 March 7, 2021 P/S + Interest / Royalty

Week 3 March 21, 2021 M&A directive

Week 4 March 28, 2021 Cross-Border Losses – Dr. Bruno Da Silva

Week 5 April 4, 2021 Free Movement of Capital (investment funds)

Week 6 April 11, 2021 ATAD, DAC 6, Abuse – Dr. Bruno da Silva

Capstone Week: Build a client case study, wrap up 

Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data (William Byrnes course material professor)

Week 1 January 13 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva & William Byrnes

Week 2 Jan 20 CUP & Comparables  Dr. Lorraine Eden

Week 3 Jan 27 Cost Plus & Resale Minus  Dr. George Salis

Week 4 Feb 3: Comparable Profits Method & TNMM Dr. George Salis

Week 5 Feb 10 Profit Split Dr. George Salis

Week 6 Feb 17 Best Method Dr. Lorraine Eden 

Transfer Pricing Risk Management: Intangibles and Services (William Byrnes course material professor)

Week 1 March 2 Intangibles Royalty Rates CUT and CPM  Dr. Debora Correa Talutto

Week 2 March 16 CSA Intangibles Buy In/Out Dr. George Salis & William Byrnes

Week 3 March 23 Digital Business Unitary Apportionment Dr. Bruno Da Silva

Week 4 March 30 Digital Value Chain, Internet of Things Dr. Lorraine Eden

Week 5 April 6 U.S. v OECD v UN Manual case study Extractive Industries, Financing Hafiz Choudhury

Week 6 April 13 Restructuring the Business, Services case study Hafiz Choudhury

Capstone Hand-On Week with Financial databases April 20 – 26: Thomson OneSource, BvD (Moodys), and CrossBorder AI Solutions Dr. Debora Correa Talutto & William Byrnes