Tax, Wealth, and Risk Management Graduate Program Blog

Professor William Byrnes (Texas A&M University School of Law)

International Tax & Transfer Pricing Certificates or LL.M. / Master Legal Studies at Texas A&M

Posted by William Byrnes on August 21, 2025


International Tax & Transfer Pricing (non-degree) Certificates or LL.M. (for law graduates) / Master Legal Studies (for accountants, economists, and financial professionals) are designed for an in-depth study of tax risk management. Texas A&M Law, as a public university, offers its graduate degree for a total tuition cost of $36,000, making it the most corporate-reimbursement/budget/investment-return-friendly competitive program in the U.S.

Sample of Courses (see graduate programs catalog)

  • Transfer Pricing l – Methods, Econometrics, and Tangibles – January start
  • Transfer Pricing II – Services and Intangibles – March start
  • International Tax Risk Management I – Data, Analytics, and Technology
  • International Taxation and Treaties I – residency issues – August start
  • International Taxation and Treaties II – source issues – October start
  • Inhouse Tax Counsel: Tax Systems and Risk Management – Summer
  • Domestic (Inbound) Tax Risk Management – August start
  • U.S. International Tax Risk Management – Data and Analytics – Spring
  • U.S. International Tax Risk Management – Law and Regulation – Summer
  • FATCA, CRS, and AEoI Risk Management – Summer
  • European Union Tax Risk Management – March start

Example of Weekly Case Study for Domestic (Inbound) Tax Risk Management Week 1 (last week of August)

A seven-week course case study, where you will serve as the new in-house international tax team, focused on its foreign operations, of Natmed Serland SA, one of the leading global FMCG Companies. The week before you must report to the office, your inhouse team has been provided Natmed’s operational briefing, department (functional) interviews briefing, and all relevant financials. Your team must come together before the first week and discuss Natmed because for your first week in the office, your team will hit the ground running. The Board of Directors has instructed the in-house tax department to brief the Operational Board weekly for one hour, over six weeks, on a specific tax risk topic area related to NatMed’s overall tax risk management and financial health. In the seventh week, at the annual Full Board meeting, your team has been granted an hour, hard-stop time slot on the agenda to provide its final tax risk management prognosis of Natmed Serland. 

Your faculty case study facilitators consist of Pramod Kumar (International Tax Director, Michelin North America); Hafiz Choudhury (M Group Principal); Dr. Maji Rhee (Dean, Center for International Education; Professor, Faculty of International Research and Education, School of International Liberal Studies, Waseda University); and the course leader Professor William Byrnes.

For week 1, Pramod Kumar, our in-house tax director expert, will lead the week 1 and week 2 learning on tax risk management concerning our fictional Natmed Serland SA, one of the world’s largest natural-healthcare groups with revenues exceeding €1.28 billion and a legacy that stretches back more than a century, earns 95 percent of its turnover outside its small European home market. Natmed’s corporate managerial and tax department briefs, the corporate financials, and ancillary research information are posted in your Canvas classroom case study folder. Please review the weekly pre-recorded video lectures and podcasts as well.

During mid-August orientation week, U.S. trade officials announce an immediate 18 percent customs duty on imported herbal creams and toothpastes—core items within Natmed’s flagship “Natmed” and “Natca” ranges. Overnight, margins on American sales collapse. During mid-August Orientation week, the chief executive summons the in-house tax team. A lifeline has appeared: the founding family of GreenLeaf Botanicals LLC, a New Jersey contract manufacturer that already toll-produces half of Natmed’s leading balm for private-label chains, is willing to sell. For USD 640 million in cash, Natmed can acquire 100 percent of GreenLeaf, re-domesticating production and escaping the new tariff. Exclusivity on the offer, however, expires in ten calendar days. The tax department must determine whether the deal truly neutralizes the duty hit, estimate the combined U.S. effective tax rate under domestic tax rules, and craft the deal’s tax covenants before the board votes. 

The chief executive officer and an operating officer (Professors Kumars and Byrnes), representing the executive team, will hold a Zoom Q&A with a representative(s) of the tax department during week 1 on Monday and Thursday evenings for corporate brainstorming (and office hour Q&A).

The executive leadership has entrusted the mandate to its in-house tax team with full autonomy—ask any questions, run any model, and decide based on the best information you can gather, submitting the report to the executive leadership before 8 pm Central time on Sunday of Week 1. The executive team will hold a Zoom presentation/Q&A with a representative(s) of the tax department on Monday evening in week 2 to discuss the tax department’s recommendations.

Week 1 Analysis and deliverables

  • As the tax department, draft a one-page “Go / No-Go” executive memorandum that frames the deal’s upside, flags the unresolved risks, and proposes a tax covenant that the board could insist on before signing. This must be submitted to the board by 8 pm Central (Dallas) on Sunday of week 1.
  • Prepare and deliver the tax department’s presentation to the executive board members’ meeting via Zoom on Monday evening. A hard-copy presentation, such as a PPT, is NOT allowed. An agenda and any show-and-tell images, if helpful for understanding the recommendations, may be provided if not clearly presented in the executive memorandum.
  • Meanwhile, William Byrnes will lead this week’s learning for U.S. international tax updates, such as the CFC’s Subpart F and NCTI regimes.  
  • Research Practicum: This week, William Byrnes will undertake a show-and-learn using the IBFD based on the case study.

Certificate and Degree candidates are exposed to (i) international tax laws, regulations, and policies in the international tax risk management field, (ii) technology and tax data management, and (iii) weekly practice case studies using Zoom and team groups. Individuals who complete the program will be able to synthesize scenarios, practice, and legal regulation in the international tax risk management field, providing analysis or judgments for consideration to organizational leadership with a nuanced perspective.

Courses are offered by asynchronous distance learning to provide a flexible schedule for working professionals. Interactive coursework includes case study assignments and regular interaction with classmates & the faculty through twice-weekly Zoom meetings (recorded), pre-recorded videos, audio casts, discussion boards, and group breakout sessions.  For more information, contact Admissions: https://www.law.tamu.edu/admissions-aid/how-to-apply/index.html

Most competitive tuition in the U.S. Texas A&M Law, as a public university, offers its graduate degree for a total tuition cost of $36,000, making it the most corporate-reimbursement/budget/investment-return-friendly competitive program in the U.S.

Top-ranked. Texas A&M law school is ranked #1 in the U.S. for employment outcomes (“gold standard” law jobs) for 2025 and 2026 – its sixth consecutive year ranked in the top 10 nationally. The law school is ranked in the first tier (#22 overall). The Wall Street Journal, focusing on career outcomes, ranks Texas A&M #12 of public universities and #1 in Texas. In addition, Texas A&M has surged to the No. 2 spot for most visible public universities and No. 8 among all U.S. institutions, according to American Caldwell’s 2025–2026 Global University Visibility (GUV) Rankings. Texas A&M’s $20 billion (2025) foundation endowment is #2 for U.S. public universities. Texas A&M has the most CEOs (#1) of Fortune 500 and Fortune 100 multinationals. Texas A&M is among the top three largest U.S. public universities, with 80,000 students enrolled in undergraduate, graduate, and doctoral/postdoctoral programs. Almost 600,000 former Aggies live worldwide and form a lifelong network across ages and academic disciplines, hosting many annual events and university-sports watch parties.

150-year old foundation. Texas A&M system’s operating budget of $9.2 billion (FY2027), R&D grants & expenditure exceed $1.5 billion, and capital budget of $6 billion includes the new billion-dollar Fort Worth integrated law-engineering-medical/public health, pharmacology, and multi-media five-building academic and research campus! Texas A&M is one of only 60 accredited universities of the Association of American Universities (R1: Doctoral Universities – Highest Research Activity) and one of only 24 universities that hold the triple crown of universities: the U.S. statutory federal grants of Land, Sea, and Space.

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