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

Leaked OECD Pillar 1 and 2 Blueprints for download

Posted by William Byrnes on September 4, 2020

OECD Leaked Pillar 1 Blue Print (pp 227)

OECD Pillar 2 Leaked Blue Print (pp 257)

This note contains a draft report on the Blueprint of the Pillar One solution expected to be delivered in October. It is distributed to the delegates of the Inclusive Framework for comments. Delegates are invited to coordinate with their teams (delegates in the TFDE and relevant working parties) to provide one consolidated set of comments per jurisdiction.

In response to repeated requests for simplifications from Inclusive Framework members, a number of simplification features were developed and discussed at the last Steering Group meeting in July and subsequently presented to the working parties. These features, which have been included in this Blueprint, have implications across different building blocks (e.g. revenue thresholds,  segmentation and profit allocation).

The draft Blueprint reflects consensus views that emerged from this work as much as possible, but recognises that certain issues, both technical and political, are still pending. There are some elements (e.g. quanta and profitability thresholds) where Inclusive Framework members will make a final decision only as part of an overall political agreement. Chapter 1 contains the executive summary of the Blueprint, and the subsequent chapters describe in more detail each building block (chapters 2 to 10). In addition, a process map illustrating how the new taxing right (Amount A) will apply in practice is provided in Annex A.


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!

FALL 2020 Semester (starts Aug 24 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 Srinivasan
    • Week 3 Oct 25 Manufacturing III (Customs) Niraja Srinivasan
    • 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

additional spring and summer courses include: 

Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data           Transfer Pricing Risk Management: Intangibles and Services

E.U. Tax Risk Management                                                                                                 U.S. Tax Risk Management

FATCA, CRS, and AEoI (Law, Data, Systems)                                                                    International Tax Risk Management I (Data, Analytics & Technology)   

VAT                                                                                                                                      Customs


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