William Byrnes' Tax, Wealth, and Risk Intelligence

10 reasons to apply for Texas A&M International Tax — request a brochure here https://info.law.tamu.edu/international-tax  (or apply online https://law.tamu.edu/distance-education/prospective-students/llm-mjur-application)

1. International Tax courses are limited to 15 students.  Many have 9 – 12 for maximum interaction with the professors and each other in real-time Zoom discussion.  No one is ‘left out’. Everyone has a substantial weekly learning experience.
2. Courses meet twice weekly on Zoom for 90 minutes (or more) to discuss the case study and the weekly issues, and then students in teams (generally of three) roll play the case study representing a stakeholder interest assigned by the professor/s in the second meeting, ending with a recap discussion of the case study. See an example case study moot on YouTube 
3. Courses include original authored reading and study materials, original case studies, links to the robust tax library for current articles, analytical materials, and technology/data providers.
4. Courses include weekly instructor video-lectures and/or audio podcasts.
5. Degree options for all tax professionals — lawyers (Master of Laws, LL.M.) and accountants, economists, financial professionals (Master of Jurisprudence, M.Jur.)
6. The founder Professor William Byrnes is the pioneer of Online Learning for Legal Education, having initiated the original version of this program in 1994 (see his LinkedIn Group of 27,000+ member network of former students, book subscribers, webinar attendees, and career contacts).
7. The founder Professor William Byrnes is a leading international tax author with 10 annual treatises published by Lexis and Wolters Kluwer, and three Tax Facts titles by National Underwriter.
8. Join the Texas A&M Aggie former student network of 500,000+ to open career and social doors (and watch Saturday SEC football games).
9. 160+ current graduate enrollment for risk management, tax-risk management, and wealth management program.
10. All students have access to Lexis, Westlaw, Bloomberg Law, Cheetah (formerly Kluwer-CCH), IBFD, Tax Analysts, S&P, BvD-Moodys, Thomson, OECD Library, and hundreds of other information resource providers (check out our university virtual libraries here and here)

Texas A&M, annual budget of $6.3 billion (FY2020), is the largest U.S. public university, one of only 60 accredited U.S. universities of the American Association of Universities (R1: Doctoral Universities – Highest Research Activity) and one of only 17 U.S. universities that hold the triple U.S. federal grant of Land, Sea, and Space!

• Ranked in top 20 public universities by Wall Street Journal / Times Higher Education (2020)
• #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
• Rank 11th “Best Public Colleges” Money’s Best Colleges Report, 2019
• Washington Monthly 2020 ranked Texas A&M No. 10 – the only institution in Texas among the top 60 – in its ranking of universities that contribute most to the public good in areas of social mobility, research, and promoting public service.

FALL 2020 Semester (starts Aug 23 and ends Nov 30) 

International Tax & Tax Treaties I: Residency Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Monday and Friday at 8am 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 U.S. Tax Reform / Pillar II
  • Week 7 capstone of tax data analytics and technology

International Tax Risk Management & Domestic Systems (Inbound) (meet Tuesdays and Sunday at 8am Central Daylight Dallas time zone)

• • Week 1 Aug 23 national tax systems in general and inbound diagnostic Dr. Susana Bokobo, former global tax policy director Repsol
  • Week 2 Aug 30 Manuel Tron Mexico as an inbound diagnostic case study (President Emeritus, International Fiscal Association)
  • Week 3 Sept 6 Elis Prendergast (KPMG)
  • Week 4 Sept 13 Carson Le (KPMG)
  • Week 5 Sept 20 Dr. Maji Rhee (Waseda) Japan/Korea as inbound case studies
  • Week 6 Sept 27 Domestic Compliance Risk Matrix Hafiz Choudhury
  • Week 7 capstone of tax data analytics and technology for inbound domestic tax risk management

International Tax & Tax Treaties II: Source Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Monday and Friday at 8am Central Daylight Dallas time zone)

• • Week 1 Oct 11 Tax of Business Income (PE, Nexus)
  • Week 2 Oct 18 Tax of Investment Income
  • Week 3: Oct 25 Taxation of Services and Employment Income (including DST)
  • Week 4: Nov 1 Double Taxation and Tax Credits
  • Week 5: Nov 8 Tax Accounting
  • Week 6: Nov 15 Introduction to Management of Tax and Data
  • Week 7 capstone of tax data analytics and technology

International Tax Risk Management II (Data, Analytics & Technology) 3 credits (meet Wednesday and Sunday at 8am Central Daylight Dallas time zone)

• • Week 1 Oct 11 Manufacturing I Dr. Niraja Srinivasan Pillar 1 (Dell Global Tax)
  • Week 2 Oct 18 Manufacturing II (DEMPE & Supply Chain) Niraja
  • Week 3 Oct 25 Manufacturing III (Customs) Niraja
  • 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
  • Week 7 capstone of tax data analytics and technology for global tax risk management

SPRING 2021 (Jan 10 – April 26, 2020 repeats 2021)

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

• • Week 1 January 10, 2021 Outbound / FDII Melissa Muhammad (IRS LB&I)
  • 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 
  • Week 7 Capstone of tax data analytics and technology for U.S. tax risk management

Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data (William Byrnes) (meet Monday and Friday at 8am Central Daylight Dallas time zone)

• • Week 1 January 10 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva & William Byrnes
  • Week 2 Jan 17 CUP & Comparables  Dr. Lorraine Eden
  • Week 3 Jan 24 Cost Plus & Resale Minus  Dr. George Salis
  • Week 4 Feb 31: Comparable Profits Method & TNMM Dr. George Salis
  • Week 5 Feb 7 Profit Split Dr. George Salis
  • Week 6 Feb 14 Best Method Dr. Lorraine Eden 

E.U. Tax Risk Management 3 credits (meet Tuesdays and Sunday at 8am 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) Dr. Bruno Da Silva
  • Week 6 April 11, 2021 ATAD, DAC 6, Abuse – Dr. Bruno da Silva
  • Week 7 capstone of tax data analytics and technology for E.U. tax risk management 

Transfer Pricing Risk Management: Intangibles and Services (William Byrnes) (meet Monday and Friday at 8am Central Daylight Dallas time zone)

• • Week 1 March 2 Intangibles Royalty Rates CUT, CPM  Dr. Debora Correa Talutto debora.talutto@veritas.com
  • 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
  • Week 7 April 20 TP technology for data analytics: Thomson OneSource, BvD (Moodys), and CrossBorder AI Solutions case-use examples led by Dr. Debora Correa Talutto (Veritas)

SUMMER 2020 (May 18 through June 30, 2020 – repeats 2021)

FATCA, CRS, and AEoI (Law, Data, Systems): 3 credits (meet 8:00am Wednesday and Sunday Central Daylight Dallas time zone)

• • Week 1. May 18: FATCA, CRS, and EU: nationality, residency, data sharing: Dr. Bruno Da Silva (Loyens & Loeff) dasilva.brunoaniceto@gmail.com.
  • Week 2. May 25: FATCA/CRS and the Asset Management Industry, intermediaries: Denise Hintzke (Deloitte) dhintzke@deloitte.com
  • Week 3. June 1: FATCA Withholding Compliance, overlap with QI: Denise Hintzke (Deloitte)
  • Week 4. June 8: Documentation FATCA v CRS: Melissa Muhammad (IRS LB&I) melissamuhammadesq@gmail.com
  • Week 5. June 15: FATCA IGAs & CRS Risk Management Melissa Muhammad melissamuhammadesq@gmail.com
  • Week 6. June 23: Financial Institutions Systems And Data: Haydon Perryman (Bank of America, UBS, Barclays, RBS and Lloyds) haydon@haydonperryman.com
  • Week 7 capstone for both Summer courses: “Tax Technology and the future of Tax Departments” Dr. Debora Correa Talutto debora.talutto@veritas.com 

International Tax Risk Management I (Data, Analytics & Technology) 3 credits (meet Tuesday at 8am and Sunday at 9:30am Central Daylight Dallas time zone)

• • Week 1. May 18: General tax risk management approach Dr. Knut Olsen   knut.tax@gmail.com
  • Week 2. May 25: BEPS: Dr. Bruno Da Silva (Loyens & Loeff).
  • Week 3. June 1: CbCR & Analytics David Deputy, Vertex david.deputy@vertexinc.com
  • Week 4. June 8: LOB / PPT / MLI: Dr. Bruno da Silva (Loyens & Loeff)
  • Week 5. June 15: Future of Analytics & Technology – Risk Management Perspective: Dr. Paula de Witte
  • Week 6. June 23: Interest (thin cap, EBIDTA), Debt/Equity Melissa Muhammad (IRS LB&I) melissamuhammadesq@gmail.com
  • Week 7 capstone for both Summer courses: “Tax Technology and the future of Tax Departments” Dr. Debora Correa Talutto debora.talutto@veritas.com

Additional courses include VAT and Customs.  20 additional courses to select from in Risk Management and Wealth Management overlapping curriculum – check out those courses and professors: