U.S. and E.U. International Tax, Transfer Pricing Courses Start Jan 19, 2021
Posted by William Byrnes on November 24, 2020
Based on weekly case studies created by the faculty, supported by reading/text materials, pre-recorded videos with PPTs, and audio podcast files made by the faculty – twice-weekly Zoom live sessions (recorded as well) of 90 – 120 minutes wherein students in teams work through the case studies generally from an assigned stakeholder perspective. Access to the extensive Texas A&M library for case study research includes by example: Lexis, Westlaw, IBFD, Kluwer-Cheetah, Thomson OneSource, BvD (Moodys), S&P CapIQ, FITCH, among several others. Apply for Texas A&M’s courses here.
- Transfer Pricing Risk Management I Tangibles, Methods, Economics, and Data
- Transfer Pricing Risk Management II: Intangibles, Services, Pillar 1/Digital, Formulary
- U.S. Tax Risk Management (Data, Analytics & Technology)
- E.U. Tax Risk Management
U.S. Tax Risk Management (Data, Analytics & Technology) syllabus
- Week 1 January 19, 2021 Outbound / FDII Melissa Muhammad (IRS LB&I)
- Week 2 January 25, 2021 Inbound / BEAT Melissa Muhammad
- Week 3 February 1, 2021 International Reporting/Technology Documentation (Forms 5471, 8865, 8858, 8832): Neelu Mehrotra: EY
- Week 4 February 8, 2021 [Understanding Subpart F & Form 5471 and 1120 Documentation}: Neelu Mehrotra: EY
- Week 5 February 15, 2021 Understanding Subpart GILTI and PTEP and Form 8992: Neelu Mehrotra: EY
- Week 6 February 22, 2021 FTCs; wrap-up: Melissa Muhammad
- Capstone Week March 1
E.U. Tax Risk Management syllabus
- Week 1 March 8, 2021 E.U. General Framework of Compliance Tax Risk Management Dr. Eva Andrés (Barcelona)
- Week 2 March 15, 2021 Parent Subsidiary Directive, Interest, Royalties. Dr. Santiago Ibañez Marcilla
- Week 3 March 22, 2021 The European Union proposal on a carbon border tax and its compatibility with the World Trade Organization rules Dr. Xavier Fernández Pons
- Week 4 March 29, 2021 Free Movement of Capital (investment funds) and others Fundamental Freedoms. Dr. Eva Andrés & Dr. Andreu Olesti
- Week 5 April 5, 2021 Cross-Border Losses – Dr. Bruno Da Silva
- Week 6 April 12, 2021 ATAD, DAC 6, Abuse – Dr. Bruno da Silva
- Capstone Week April 19-25: Build a client case study, wrap up
Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data (William Byrnes course materials) syllabus
- Week 1 January 19 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva & William Byrnes
- Week 2 Jan 25 CUP & Comparables Dr. Lorraine Eden
- Week 3 Feb 1 Cost Plus & Resale Minus Dr. George Salis
- Week 4 Feb 8: Comparable Profits Method & TNMMDr. George Salis
- Week 5 Feb 15 Profit Split Dr. George Salis
- Week 6 Feb 22 Best Method Dr. Lorraine Eden
- Capstone Week March 1
Transfer Pricing Risk Management: Intangibles and Services (William Byrnes course materials) syllabus
- Week 1 March 8 Intangibles Royalty Rates CUT, CPM Dr. Debora Correa Talutto
- Week 2 March 15 CSA Intangibles Buy In/Out Dr. George Salis & William Byrnes
- Week 3 March 22 Digital Business Unitary Apportionment Dr. Bruno Da Silva
- Week 4 March 29 Digital Value Chain, Internet of Things Dr. Lorraine Eden
- Week 5 April 5 U.S. v OECD v UN Manual case study Extractive Industries, Financing Hafiz Choudhury
- Week 6 April 12 Restructuring the Business, Services case study Hafiz Choudhury
- Week 7 April 19 Capstone Hand-On Week with Financial databases “Tax Technology and the future of Transfer Pricing” Dr. Debora Correa Talutto Thomson OneSource, BvD (Moodys), and CrossBorder AI Solutions Dr. Debora Correa Talutto & William Byrnes
Texas A&M, an 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
- Texas A&M ranks #1 in Texas, #1 in the SEC, and #12 in the U.S. in Washington Monthly’s 2020 overall college rankings based on the quality of education, accessibility, graduation rates, student involvement, and research: see tx.ag/WashMonth20
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