William Byrnes' Tax, Wealth, and Risk Intelligence

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

International Tax Risk Management course descriptions

Posted by William Byrnes on November 5, 2020


Courses are limited to maximum 30 participants: Application 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 COURSES

Int’l Taxation & Treaties I

Course description: This course, focused on residency-based taxation, and its companion focused on source-based taxation, is the primer for the concentration area of risk management addressing the tax function within a multinational enterprise (thus, aptly named international tax risk management). This course and the others within the tax risk management concentration provide a comparative overview of the tax law and accounting of significant trade nations, an overview of the application of tax treaties among countries, and a global holistic perspective for multinational tax risk planning. The course is taught synchronously twice weekly using Zoom. Each week teams of 3-4 students, each with a chosen team role (e.g. develop PPT, develop presentation notes, make presentation), are assigned by the professor a stakeholder role to develop in the context of a case study.  The professors moderate the teams that discuss and moot with each other during a weekly live presentation session.  Teams generally use PPT and other presentation aids. The primary purpose of the course is to allow students to work through real world tax scenarios considering the planning risks and management of those risks. This course is co-taught by Professor William Byrnes who authored the course materials and Dr. Bruno da Silva.

Int’l Taxation & Treaties II

Course Description: This second course in a series of two courses is focused on sourced based taxation. The first course is focused on residency-based taxation. Together these courses are the primer for the concentration area of risk management addressing the tax function within a multinational enterprise(thus, aptly international tax risk management).This course and the others within the tax risk management concentration provide a comparative overview of the tax law and accounting of significant trade nations, an overview of the application of tax treaties among countries, and a global holistic perspective for multinational tax risk planning. The course is taught synchronously twice weekly using Zoom. Each week teams of 3-4 students, each with a chosen team role (e.g. develop PPT, develop presentation notes, make presentation), are assigned by the professor a stakeholder role to develop in the context of a case study.  The professors moderate the teams that discuss and moot with each other during a weekly live presentation session.  Teams generally use PPT and other presentation aids. The primary purpose of the course is to allow students to work through real world tax scenarios considering the planning risks and management of those risks. This course is co-taught by Professor William Byrnes who authored the course materials and Dr. Bruno da Silva.

Domestic Systems International Tax Risk Management  

Course Description: Tax Risk Management: Domestic (Inbound) addresses the interaction of international taxation risk management and domestic systems.  This course continues with the tax diagnostic process started in International Tax & Treaties I and II, and the tax data risk analytics exposed to in International Tax Risk Management I, bringing tax data analytics into the domestic system diagnostic, and how technology supports the inbound tax investment analysis. The course is taught synchronously twice weekly using Zoom. Each week teams of 3-4 students, each with a chosen team role (e.g. develop PPT, develop presentation notes, make presentation), are assigned by the professor a stakeholder role to develop in the context of a case study.  The professors moderate the teams that discuss and moot with each other during a weekly live presentation session.  Teams generally use PPT and other presentation aids. The primary purpose of the course is to allow students to work through real world tax scenarios considering the planning risks and management of those risks. This course is co-taught by a team of professors including Dr. Susana Bokobo, Dr. Maji Rhee, Elis Prendergast, Carson Le, and Hafiz Choudhury, supported by the authored materials of Professor William Byrnes.

Int’l Tax Risk Management II (Data, Analytics & Technology)

Course description: Int’l Tax Risk Management II Data, Analytics & Technology addresses the interaction of international taxation risk management, data, technology, and analytics.  Tax Risk Management II addresses the following issues: global supply chain and value allocation/apportionment, DEMPE, customs, taxation of IP and technology, and tax technology.  This course completes the trilogy of tax risk management courses and overlays the tax diagnostic process learned in International Tax & Treaties I and II, bringing tax data analytics into the diagnostic, and how technology supports a risk-based approach to managing the tax burden of a multinational. This course is co-taught by Dr. Niraja Srinivasan and Dr. Brigitte Muehlmann.

SPRING COURSES

Transfer Pricing Risk Management I: Tangibles, Methods, Economics, and Data

Course description: This course introduces students to both theoretical and practical aspects of transfer pricing.  Topics include: valuation of cross-border transactions between units of a multinational enterprise; includes internal and external motivations for transfer pricing, managerial and economic approaches, estimates of transfer manipulation, arm’s length standard, U.S. and OECD rules and procedures, tax court cases, and ethical dilemmas. The expanding influence of the UN Manual’s approach to transfer pricing issues is contrasted throughout the main topics. Each week, an industry-based case study is undertaken in a team-based learning approach of student groups consisting of three team members each.  The industry case studies by example include Coffee, Technology, and Petroleum.

This course (Part I) is meant to be taken as the introduction with Transfer Pricing Part II as the advanced perspective.  Part I and Part II topics address strategy, compliance, and risk management.  Transfer Pricing Part I focuses on the topics of comparability, functional analysis and global value chain analysis, and the transfer pricing methods for tangibles and on data documentation (e.g. CbCR). Transfer Pricing Part II focuses on the transfer pricing methods applicable for intangibles and services. This course is led by Professor William Byrnes who has assembled a team including Dr. Lorraine Eden, Dr. George Salis, and Dr. Bruno Da Silva.

Transfer Pricing Risk Management II: Intangibles and Services

Course description: Topics include: valuation of cross-border transactions between units of a multinational enterprise; includes internal and external motivations for transfer pricing, managerial and economic approaches, estimates of transfer manipulation, arm’s length standard, U.S. and OECD rules and procedures, tax court cases, and ethical dilemmas. The expanding influence of the UN Manual’s approach to transfer pricing issues is contrasted throughout the main topics. Each week, an industry-based case study is undertaken in a team based learning approach of student groups consisting of three team members each.  The industry case studies by example include Coffee, Technology, and Petroleum.

This course is meant to be taken with Transfer Pricing Part I.  Part I and Part II topics address strategy, compliance, and risk management.  Transfer Pricing Part II focuses on the topics of comparability, functional analysis and global value chain analysis, and the transfer pricing methods for tangibles and services. Transfer Pricing Part II focuses on the transfer pricing methods applicable for intangibles, and on documentation (e.g. CbCR).  This course is led by Professor William Byrnes who has assembled a team including Dr. Lorraine Eden, Dr. George Salis, Dr. Debora Correa Talutto, Dr. Bruno Da Silva, and Hafiz Chouhury.

EU Tax Risk Management

Course description: The primary focus of the course will be on the E.U. general framework of compliance tax risk management. This includes: Parent Subsidiary Directive, Interest, Royalties, The European Union proposal on a carbon border tax and its compatibility with the World Trade Organization rules, Free Movement of Capital (investment funds) and others Fundamental Freedoms, Cross-Border Losses, ATAD, DAC 6, and Abuse of Law. The course is taught synchronously twice weekly using Zoom. Each week teams of 3-4 students, each with a chosen team role (e.g. develop PPT, develop presentation notes, make presentation), are assigned by the professor a stakeholder role to develop in the context of a case study.  The professors moderate the teams that discuss and moot with each other during a weekly live presentation session.  Teams generally use PPT and other presentation aids. The primary purpose of the course is to allow students to work through real world tax scenarios considering the planning risks and management of those risks. This course is taught by a team that includes Dr. Eva Andrés, Dr. Santiago Ibañez Marcilla, Dr. Xavier Fernández Pons, Dr. Andreu Olesti, and Dr. Bruno da Silva.

U.S. International Tax Risk Management

Course description: This course considers the basic principles and policies governing the US taxation of international transactions using a risk management case-study approach addressing data.  Consideration will be given to both inbound (foreign investment in the US) and outbound (US investment abroad) transactions. We will analyze the US tax rules and the interaction between US and foreign tax systems through the operation of the tax credit and tax treaties, and more. Topics include: Outbound / FDII, Inbound / BEAT, Form 1120 Documentation and Check the Box, Subpart F & GILTI, PTEP, Form 5471, M&A and finally, FTCs. The course is taught synchronously twice weekly using Zoom. Each week teams of 3-4 students, each with a chosen team role (e.g. develop PPT, develop presentation notes, make presentation), are assigned by the professor a stakeholder role to develop in the context of a case study.  The professors moderate the teams that discuss and moot with each other during a weekly live presentation session.  Teams generally use PPT and other presentation aids. The primary purpose of the course is to allow students to work through real world tax scenarios considering the planning risks and management of those risks. This course is co-taught by Melissa Muhammad and Neelu Mehrotra.

SUMMER COURSES

FATCA, CRS, AEoI and Tax Data Analytics

Course description: This course addresses the tax and compliance issues, then data collection, remediation, maintenance, and analytics issues of FATCA, CRS, and other types of AEoI.  The course is taught synchronously twice weekly using Zoom. Each week teams of 3-4 students, each with a chosen team role (e.g. develop PPT, develop presentation notes, make presentation), are assigned by the professor a stakeholder role to develop in the context of a case study.  The professors moderate the teams that discuss and moot with each other during a weekly live presentation session.  Teams generally use PPT and other presentation aids. The primary purpose of the course is to allow students to work through real world tax scenarios considering the planning risks and management of those risks. The course materials are excerpted from William Byrnes’ treatise on FATCA and CRS. Learnings aids include weekly Camtasia videos covering the weekly PPT and case studies, supported by recorded audio podcasts. The professor team for this course includes: Professor William Byrnes who has prepared the course based on his treatise materials, Denise Hintzke, Melissa Muhammad, and Haydon Perryman.

Int’l Tax Risk Management I (Data, Analytics & Technology)

Course description: Int’l Tax Risk Management I introduces the Data, Analytics & Technology addresses the interaction of international taxation risk management, data, technology, and analytics.  Tax Risk Management II addresses the following issues: global supply chain and value allocation/apportionment, DEMPE, customs, taxation of IP and technology, and tax technology.  This course completes the trilogy of tax risk management courses and overlays the tax diagnostic process learned in International Tax & Treaties I and II, bringing tax data analytics into the diagnostic, and how technology supports a risk-based approach to managing the tax burden of a multinational. The course is taught synchronously twice weekly using Zoom. Each week teams of 3-4 students, each with a chosen team role (e.g. develop PPT, develop presentation notes, make presentation), are assigned by the professor a stakeholder role to develop in the context of a case study.  The professors moderate the teams that discuss and moot with each other during a weekly live presentation session.  Teams generally use PPT and other presentation aids. The primary purpose of the course is to allow students to work through real world tax scenarios considering the planning risks and management of those risks. This course is co-taught by a team of professors including Dr. Knut Olson, Dr. Bruno Da Silva, David Deputy, Dr. Paula de Witte, Melissa Muhammad and Dr. Debora Correa Talutto.

Customs, Excise, VAT, GST, Sales and Risk Management

Course description: This course focuses on indirect taxation and its risk management.  The course will address importation of good, services, and intangibles from the perspective of a customs and a VAT regime. VAT sourcing rules, inputs and outputs will be described, and management of the tax risks emanating from overlapping regimes and complex supply chains.  The course is taught synchronously twice weekly using Zoom. Each week teams of 3-4 students, each with a chosen team role (e.g. develop PPT, develop presentation notes, make presentation), are assigned by the professor a stakeholder role to develop in the context of a case study.  The professors moderate the teams that discuss and moot with each other during a weekly live presentation session.  Teams generally use PPT and other presentation aids. The primary purpose of the course is to allow students to work through real world tax scenarios considering the planning risks and management of those risks.

International Tax Risk Management III (Planning)

Course description: This course represents the capstone of the curriculum of tax risk management. This course presents complex MNE scenarios that require multiple tax mitigation scenarios, and thus corresponding risk assessment for each scenario. Multiple tax issues will overlap, the foundation of those issues addressed in the previous courses. The course is taught synchronously twice weekly using Zoom. Each week teams of 3-4 students, each with a chosen team role (e.g. develop PPT, develop presentation notes, make presentation), are assigned by the professor a stakeholder role to develop in the context of a case study.  The professors moderate the teams that discuss and moot with each other during a weekly live presentation session.  Teams generally use PPT and other presentation aids. The primary purpose of the course is to allow students to work through real world tax scenarios considering the planning risks and management of those risks.

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