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FATCA & CRS (Law, Data, Systems); International Tax Risk Management I (Data, Analytics & Technology) May 24 – July 11. Apply now

Posted by William Byrnes on February 9, 2021


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 for persons who cannot attend) 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.

FATCA, CRS, and AEoI (Law, Data, Systems): 3 credits  

  • Week 1. May 17: FATCA, CRS, and EU: nationality, residency, data sharing: Dr. Bruno Da Silva (Loyens & Loeff) dasilva.brunoaniceto@gmail.com.
  • Week 2. May 24: FATCA/CRS and the Asset Management Industry, intermediaries: Denise Hintzke (Deloitte) dhintzke@deloitte.com
  • Week 3. May 31: FATCA Withholding Compliance, overlap with QI: Denise Hintzke (Deloitte)
  • Week 4. June 7: Documentation FATCA v CRS: Melissa Muhammad (IRS LB&I) melissamuhammadesq@gmail.com
  • Week 6. June 21: Financial Institutions Systems And Data:
  • Week 7 June 28 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

  • 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 7 capstone for both Summer courses: “Tax Technology and the future of Tax Departments” Dr. Debora Correa Talutto debora.talutto@veritas.com
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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!

The official School of Law graduate enrollment for the Spring 2021 semester is 487 degree-seeking students. The university enrollment is 68,000+ degree seekers.

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Transfer Pricing Risk Management Zoom Team-Based Case Studies Start Tuesday, Jan 19, run until May

Posted by William Byrnes on January 8, 2021


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.

Professor William Byrnes’ leverages the expertise of weekly case study experts that draw from a variety of disciplines including accounting, economics, finance, international business, management, and law. The textbook is authored by Professor William Byrnes and provided within the course [William Byrnes, Practical Guide to Transfer Pricing, 4th ed, 2021 version, published by Matthew Bender via LexisNexis and available in the law library in hardcopy].

Transfer pricing is the valuation of cross-border transactions between units of a multinational enterprise. This course introduces students to both theoretical and practical aspects of transfer pricing. This course deep dives into the legal issues (regulations and jurisprudence); accounting systems and variances among (managerial, financial, tax, and public accounting); financial data analytics through the lens of economic methods and profit level indicators; functional analysis and global value chain; contrasts with the OECD Transfer Pricing Guidelines and UN Transfer Pricing Manual. Each week, an industry-based case study is undertaken in a team-based learning approach of student groups generally consisting of three team members each.  The industry case studies include, as examples, agriculture (coffee supply chain), technology services, and petroleum.

Part I and Part II of this course both address strategy, compliance, and risk management.  Transfer Pricing Part I focuses on the topics of comparability, the transfer pricing methods, functional analysis and global value chain analysis, and transfer pricing analysis for tangibles. Transfer Pricing Part II focuses on the transfer pricing methods and analysis for intangibles and for services. Topics more specifically that are addressed in this course via its textbook, video and audio lectures, weekly team-based case studies, and weekly live sessions, include the arm’s length standard, comparability analysis, risk analysis for tangibles and intangibles, transactional methods (CUP, CUT, Cost Plus, Resale Minus, Commodity), profit methods (e.g. comparable profits method, transactional net margin method, profit level indicators, key performance indicators, commensurate with income), functional analysis (supply chain, global value chain analysis, DAEMPE functions), industry economic data gathering and analysis, cost-sharing arrangements, profit splits and residuals, platform contributions, and safe harbors.  Documentation, advance pricing agreement procedures, and mutual agreement procedures are topics addressed in the courses of “International Tax Risk Management I” and of “FATCA, CRS, and CbCR”. Apply for Texas A&M’s courses here.

Course Topics and Calendar

Week 1 January 19 Arm’s Length Standard case study by Dr. Bruno da Silva

Jan 19 Tuesday at 9am – 10:30am (2-minute student introductions, orientation to teamwork and case studies, expectations and obligations regarding participation asynchronously or synchronously, discuss the syllabus, set up first-week case study)

Jan 24 Sunday at 10am – noon (presentations, peer feedback)

Week 2 Jan 26: CUP & Comparables, Eden Hofert – the Christmas Tree case (Canadian)/Compaq by Dr. Lorraine Eden

Jan 26 Tuesday at 9am – 10:30am (2-minute student introductions, orientation to teamwork and case studies, expectations and obligations regarding participation asynchronously or synchronously, discuss syllabus, set up first week case study)

Jan 29 Friday at 9am – 10:30 (presentations, peer feedback)

Week 3 Feb 2: Cost Plus & Resale Minus (Byrnes’ Starbucks case study) by Dr. George Salis

Feb 2 Tuesday at 9am – 10:30am

Feb 7 Sunday at 10am – 11:30 (presentations, peer feedback)

  • Watch background and overview videos of big data & econometrics as it is used in transfer pricing.
  • Read textbook Chapter 7 then read chapter 6.
  • Contrast the analysis within the Cost Plus Method and Resale Minus Method cases.
  • Each team has a stakeholder role in Byrnes’ case study of Starbucks cost inclusion and exclusion, agriculture supply chain, and coffee global value chain.

Week 4 Feb 9: Comparable Profits Method & TNMM by Dr. George Salis

Feb 9 Tuesday at 9am – 10:30am (discussion about Byrnes’ case study and the CPM)

Feb 14 Sunday at 10am – 11:30 (presentations, peer feedback)

  • Read textbook chapters 8 and 9.
  • Watch second set of videos of big data & econometrics.
  • Review the CPM/TNMM examples.
  • Teams prepare the Case Study.

Week 5 Feb 16: functional analysis & global value chain, profit split methods by Dr. George Salis

Feb 16 Tuesday at 9am – 10:30am (discussion about Byrnes’ case study and the CPM, GVC)

Feb 21 Sunday at 10am – 11:30 (presentations, peer feedback)

  • Read textbook chapters 11 and 12, skim chapters 97 and 98
  • Watch videos about FA and GVC.
  • Review the GVC examples (chapters from textbook regarding coffee, technology, tobacco).
  • Team’s prepare the Case Study.

Week 6 Feb 23 Best Method – Snowin’ and Blowin’ case study by Dr. Lorraine Eden

Feb 23 Tuesday at 9am – 10:30am

Feb 26 Friday at 9am – 10:30 (presentations, peer feedback)

  • Read textbook chapters 15 and 16
  • Watch video.
  • Team’s prepare the Case Study.

Week 7 March 2 Capstone summation and tax risk technology presentations

March 2 Tuesday at 9am – 10:30am (counsel litigation discussion)

March 5 Friday at 9am – 10:30 (tech provider training)

Week 8 March 15: Intangibles Royalty Rates CUT and CPM by Dr. Debora Talutto

March 16 Tuesday at 9am – 10:30am (counsel litigation discussion)

March 21 Sunday at 10am – 11:30 (tech provider training)

  • Read textbook chapter 10
  • Analyze the CUT cases
  • Case Study presentation

Week 9 March 22: Intangibles Buy In/Out Cost Sharing Arrangements, Platform Contribution Transactions by Dr. George Salis

March 23 Tuesday at 9am – 10:30am

March 28 Sunday at 10am – 11:30 (presentations, peer feedback)

  • Read textbook chapter 13
  • Analyze the CSA/PCT cases
  • Case Study presentations

Week 10 March 29: Digital; Unitary Apportionment; Pillar 1; EU State Aid

by Dr. Bruno da Silva dasilva.brunoaniceto@gmail.com

March 30 Tuesday at 9am – 10:30am

April 2 Friday at 9am – 10:00 (presentations, peer feedback)

  • Read textbook chapters 44 and 75
  • Review Pillar One
  • Case Study presentation

Week 11 April 5: Digital –Amazon, Internet of Things (IOT) by Dr. Lorraine Eden and Dr. Niraja Srinivasan

April 6 Tuesday at 9am – 10:30am

April 9 Friday at 9am – 10:00 (presentations, peer feedback)

  • Read OECD Pillar 1 comment letters in the course folder
  • Read Lorraine Eden’s articles
  • Read Chapter 46

Week 12: April 12 Services by Hafiz Choudhury

April 13 Tuesday at 9am – 10:30am

April 16 Friday at 9am – 10:00 (presentations, peer feedback)

Week 13 April 19: Restructuring (and extractive industry experience) by Hafiz Choudhury

April 20 Tuesday at 9am – 10:30am

April 23 Friday at 9am – 10:00 (presentations, peer feedback)

  • Read textbook chapters 27, 43
  • In the second week, the investors find out that the state owned off take customer is not utilizing the full capacity of the FSRU

Week 14 April 26 Capstone presentations for comment letters

April 27 Tuesday at 9am – 10:30am

April 30 Friday at 9am – 10:00 (presentations, peer feedback)

  • Review past comment letter submissions
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!

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U.S. / E.U. International Tax Risk Management Zoom Team-Based Case Studies Start Jan 19 – April 25 (14 weeks)

Posted by William Byrnes on December 9, 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

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

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!

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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

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

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!

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Earn your Texas A&M Transfer Pricing certificate w/ live team-based weekly case studies starting January 19

Posted by William Byrnes on November 11, 2020


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

The back-to-back courses are limited to a maximum 30 certificate participants and degree seekers: Application HERE

William Byrnes, author of the leading transfer pricing treatise, leads a team of hands-on transfer pricing professionals and professors (see links below) who created weekly case studies for teams to work through, facilitated by Zoom on Tuesday at 9am Central (Dallas) time and Fridays at 9am (live session lasts at least 90 minutes and is recorded, available to students until May 1 (then deleted in compliance with FERPA and other rights). The Teams present their proposals and results critiqued and discussed by the teams and professors. See example live session on YouTube here

  • Week 1 January 19 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva
  • 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
  • Week 7 Capstone March 1 (Hands-On Week with Financial Databases for Comparables Management) Dr. Debora Correa Talutto Thomson OneSource, BvD (Moodys), and CrossBorder AI Solutions Dr. Debora Correa Talutto
  • Week 8 March 8 Intangibles Royalty Rates CUT, CPM Dr. Debora Correa Talutto
  • Week 9 March 15 CSA Intangibles Buy In/Out Dr. George Salis
  • Week 10 March 22 Digital Business Unitary Apportionment Dr. Bruno Da Silva
  • Week 11 March 39 Digital Value Chain, Internet of Things Dr. Lorraine Eden
  • Week 12 April 5 U.S. v OECD v UN Manual case study Extractive Industries, Financing Hafiz Choudhury
  • Week 13 April 12 Restructuring the Business, Services case study Hafiz Choudhury
  • Week 14 Capstone April 19 Hand-On Week with Tax Technology to Manage Risk William Byrnes
  • Other guest experts/professors will be joining with case studies

Weekly course materials include in the tuition: the Lexis textbook and supplement materials, pre-recorded videos with PPTs, and audio podcast files made by the faculty (listen at the gym or when driving). Access to the extensive Texas A&M library for case study research includes as some examples: Lexis, Westlaw, IBFD, Kluwer-Cheetah, Thomson OneSource, BvD (Moodys), and S&P CapIQ.

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!

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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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USA and EU international tax case studies start on January 19

Posted by William Byrnes on October 19, 2020


U.S. Tax Risk Management (Data, Analytics & Technology) (Zoom Wednesday and Sunday at 8am Central Standard Dallas time zone)

E.U. Tax Risk Management 3 credits (Zoom Wednesday and Sunday at 8am Central Daylight Dallas time zone)

  • Week 1 March 8, 2021 General Framework & Fundamental Freedoms
  • Week 2 March 15, 2021 P/S + Interest / Royalty
  • Week 3 March 22, 2021 M&A directive
  • Week 4 March 29, 2021 Free Movement of Capital (investment funds) 
  • Week 5 April 5, 2021 Cross-Border Losses
  • Week 6 April 12, 2021 ATAD, DAC 6, Abuse
  • Capstone Week April 19: tax compliance and technology

Weekly course materials include the written materials, pre-recorded videos, PPTs, and audio files (listen at the gym or when driving). Access to the extensive Texas A&M library for case study research includes as examples: Lexis, Westlaw, IBFD, Kluwer-Cheetah, Thomson OneSource, BvD (Moodys), and S&P CapIQ.

Courses are limited to maximum 20 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!

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14 transfer pricing case studies start on January 19

Posted by William Byrnes on October 16, 2020


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

William Byrnes, author of the leading transfer pricing treatise, lead professor. Weekly case study teams work through, facilitated (Zoom) with a weekly expert/professor on Mondays at 9am Central (Dallas) time and then on Fridays at 9am the Teams present their proposals and results critiqued and discussed by the teams and professors.

  • Week 1 January 19 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva
  • 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
  • Week 7 Capstone March 1 (Hands-On Week with Financial Databases for Comparables Management) Dr. Debora Correa Talutto Thomson OneSource, BvD (Moodys), and CrossBorder AI Solutions Dr. Debora Correa Talutto
  • Week 8 March 8 Intangibles Royalty Rates CUT, CPM Dr. Debora Correa Talutto
  • Week 9 March 15 CSA Intangibles Buy In/Out Dr. George Salis
  • Week 10 March 22 Digital Business Unitary Apportionment Dr. Bruno Da Silva
  • Week 11 March 39 Digital Value Chain, Internet of Things Dr. Lorraine Eden
  • Week 12 April 5 U.S. v OECD v UN Manual case study Extractive Industries, Financing Hafiz Choudhury
  • Week 13 April 12 Restructuring the Business, Services case study Hafiz Choudhury
  • Week 14 Capstone April 19 Hand-On Week with Tax Technology to Manage Risk William Byrnes
  • Other guest experts/professors will be joining with case studies

Weekly course materials include the written materials, pre-recorded videos, PPTs, and audio files (listen at the gym or when driving). Access to the extensive Texas A&M library for case study research includes as examples: Lexis, Westlaw, IBFD, Kluwer-Cheetah, Thomson OneSource, BvD (Moodys), and S&P CapIQ.

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!

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Lecture and Live Class Videos from Transfer Pricing January 11 through April 30

Posted by William Byrnes on September 29, 2020


Texas A&M University School of Law’s online international tax risk management graduate curricula for industry professionals. Over 350 lawyers or accountants or economists are enrolled for Texas A&M Law’s graduate online programs – BUT sections remain 30 and under for maximum engagement among students and faculty per section.  Apply now for courses that begin January 11 spring semester.  

Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data (William Byrnes lead professor, weekly leader below, several other guests join for discussions and case studies) Team-based case studies are live each Monday and Friday at 9am Central time.

  • Week 1 January 13 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva 
  • Week 2 Jan 20 CUP & Comparables  Dr. Lorraine Eden
  • Week 3 Jan 27 Cost Plus & Resale Minus  Dr. George Salis
  • Week 4 Feb 3: Comparable Profits Method & TNMM Dr. George Salis
  • Week 5 Feb 10 Profit Split Dr. George Salis
  • Week 6 Feb 17 Best Method Dr. Lorraine Eden 

Transfer Pricing Risk Management: Intangibles and Services (William Byrnes lead professor) Team-based case studies are live each Monday and Friday at 9am Central time.

  • Week 1 March 2 Intangibles Royalty Rates CUT, CPM  Dr. Debora Correa Talutto
  • Week 2 March 16 CSA Intangibles Buy In/Out Dr. George Salis
  • 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 Capstone Hand-On Week with Financial databases “Tax Technology and the future of Transfer Pricing” Dr. Debora Correa Talutto April 20 – 26: Thomson OneSource, BvD (Moodys), and CrossBorder AI Solutions Dr. Debora Correa Talutto & William Byrnes

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

  • Week 1 January 10, 2021 Outbound / FDII Melissa Muhammad (IRS LB&I) melissamuhammadesq@gmail.com
  • Week 2 January 17, 2021 Inbound / BEAT Melissa Muhammad
  • Week 3 January 24, 2021 [check the box] Form 1120 Documentation: Neelu Mehrotra: EY mehrotra.neelu@gmail.com
  • 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 

E.U. Tax Risk Management 3 credits (Tuesday and Sunday at 8am Central 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
  • Week 5 April 4, 2021 Free Movement of Capital (investment funds)
  • Week 6 April 11, 2021 ATAD, DAC 6, Abuse – Dr. Bruno da Silva
  • Capstone Week: Build a client case study, wrap up

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!

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Transfer Pricing Risk Management I and II January 11 – April 30. Weekly Case studies on Tangibles, Intangibles, Methods, Economics, and Data Analytics

Posted by William Byrnes on September 25, 2020


Texas A&M University School of Law’s online international tax risk management graduate curricula for industry professionals has attracted over 160 enrollment this fall semester. Apply now for courses that begin January 11 spring semester. See example case study team based discussions, library access, meet the faculty via the YouTube link weekly topic 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!

Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data (William Byrnes lead professor, weekly leader below, several other guests join for discussions and case studies)

Team-based case studies are live each Monday and Friday at 9am Central time.

  • Week 1 January 13 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva 
  • Week 2 Jan 20 CUP & Comparables  Dr. Lorraine Eden
  • Week 3 Jan 27 Cost Plus & Resale Minus  Dr. George Salis
  • Week 4 Feb 3: Comparable Profits Method & TNMM Dr. George Salis
  • Week 5 Feb 10 Profit Split Dr. George Salis
  • Week 6 Feb 17 Best Method Dr. Lorraine Eden 

Transfer Pricing Risk Management: Intangibles and Services (William Byrnes lead professor) Team-based case studies are live each Monday and Friday at 9am Central time.

  • Week 1 March 2 Intangibles Royalty Rates CUT, CPM  Dr. Debora Correa Talutto
  • Week 2 March 16 CSA Intangibles Buy In/Out Dr. George Salis
  • 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 Capstone Hand-On Week with Financial databases “Tax Technology and the future of Transfer Pricing” Dr. Debora Correa Talutto April 20 – 26: Thomson OneSource, BvD (Moodys), and CrossBorder AI Solutions Dr. Debora Correa Talutto & William Byrnes

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

  • Week 1 January 10, 2021 Outbound / FDII Melissa Muhammad (IRS LB&I) melissamuhammadesq@gmail.com
  • Week 2 January 17, 2021 Inbound / BEAT Melissa Muhammad
  • Week 3 January 24, 2021 [check the box] Form 1120 Documentation: Neelu Mehrotra: EY mehrotra.neelu@gmail.com
  • 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 

E.U. Tax Risk Management 3 credits (Tuesday and Sunday at 8am Central 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
  • Week 5 April 4, 2021 Free Movement of Capital (investment funds)
  • Week 6 April 11, 2021 ATAD, DAC 6, Abuse – Dr. Bruno da Silva
  • Capstone Week: Build a client case study, wrap up

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Team Based International Tax Case Studies Start August 24th – Apply to Join

Posted by William Byrnes on August 3, 2020


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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10 reasons to apply for Texas A&M International Tax Risk Management

Posted by William Byrnes on July 16, 2020


— request a brochure https://info.law.tamu.edu/international-tax  

  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 discussions. 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 weekly case study moot on YouTube 
  3. Courses include bespoke authored textbooks and study materials and original case studies by the faculty.
  4. Courses include bespoke authored weekly video-lectures and/or audio podcasts by the faculty.
  5. All students have access to Lexis, Westlaw, Bloomberg LawCheetah (formerly Kluwer-CCH), IBFDTax AnalystsS&PBvD-MoodysThomsonOECD Library, and hundreds of other information resource providers (check out our university virtual libraries here and here)
  6. Degree options for all tax professionals — lawyers (Master of Laws, LL.M.) and accountants, economists, financial professionals (Master of Jurisprudence, M.Jur.)
  7. 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).
  8. 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. See his list of publications and over 1,100 media tax articles here.
  9. Join the Texas A&M Aggie former student network of 500,000+ to open career and social doors (and watch Saturday SEC football games) with Aggie Clubs throughout 100 countries in major cities.
  10. 160+ graduate students currently enrolled for risk management, tax-risk management, and wealth management program, many with 10+ years experience, to build your career network today.

 

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!

 

 

International Tax & Tax Treaties I: Residency                                                                    International Tax & Tax Treaties I: Source    

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 & Domestic Systems (Inbound)

International Tax Risk Management I (Data, Analytics & Technology)                         International Tax Risk Management II (Data, Analytics & Technology)

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Byrnes & Bloink’s TaxFacts Intelligence Weekly (Friday July 9, 2020)

Posted by William Byrnes on July 10, 2020


Texas A&M University School of Law has launched its online international tax risk management graduate curricula for industry professionals.

Apply now for courses that begin August 23: International Tax Risk Management, Data, and Analytics; International Tax & Tax Treaties (complete list here

Texas A&M University is a public university, ranked in the top 20 universities by the Wall Street Journal / Times Higher Education university rankings, and is ranked 1st among public universities for its superior education at an affordable cost (Fiske, 2018) and ranked 1st of Texas public universities for best value (Money, 2018).

 

 

Prof. William H. Byrnes
        Robert Bloink, J.D., LL.M.

Hope everyone had a great 4th last weekend! This week we analyze more CARES Act developments in the form of an extension of the RMD waiver to cover all of 2020. This potentially helps account holders who took RMDs prior to the passage of the CARES Act. We also see new proposed regs that define “real property” for the purposes of 1031 exchanges, as well extended deadlines related to opportunity zones.

New Regs Define Real Property for 1031 Exchanges

The 2017 tax reform legislation limited the availability of Section 1031 exchanges to exchanges of real property. Despite this, the important term “real property” had never actually been defined for 1031 purposes. The proposed regulations adopt a new definition of real property and make clear that each separate asset involved in a transaction must be analyzed independently to determine whether it qualifies. For more information on these definitions, visit Tax Facts Online. Read More

IRS Expands RMD Waiver Relief for All of 2020

Despite this, the law was enacted after some taxpayers had already taken their 2020 RMDs early in the year. For those who took RMDs very early in the year, the sixty-day rollover period had already expired. In response, the IRS announced that anyone who took a 2020 RMD is eligible to roll the funds back into their account penalty-free. The sixty-day rollover period was extended through August 31, 2020, so clients still have only a limited period of time in which to act. Further, the rollover does not count toward the otherwise applicable “one rollover per twelve-month period” rule or the restriction on rollovers for inherited IRAs. For more information on the RMD rules, visit Tax Facts Online. Read More

Key Deadlines for Opportunity Zone Investments Extended
As is the case with many deadlines this spring and summer, the IRS has extended several key deadlines that apply to opportunity zone investments. For taxpayers whose last day of the 180-day investment period within which to make a QOZF investment was on or after April 1, 2020 and before December 31, 2020, the last day of the 180-day period is extended to December 31, 2020. QOFs that failed to satisfy the 90 percent investment rule for a period ending on or after April 1, 2020 and on or before December 31, 2020 will not be subject to a penalty (i.e., the failure is disregarded). Similarly, the 30-month substantial improvement period for tangible property that is used prior to being acquired is suspended between April 1, 2020 and December 31, 2020. For more information on opportunity zones and extended deadlines, visit Tax Facts Online. Read More

 

Byrnes & Bloink’s Tax Facts Offers a Complete Web, App-Based, and Print Experience

Reducing complicated tax questions to understandable answers that can be immediately put into real-life practice, Tax Facts works when and where you need it….on your desktop, at home on your laptop, and on the go through your tablet or smartphone.

  • all Tax Facts books
  • Tax Facts Intelligence weekly newsletters
  • weekly strategy articles for client advisory
  • weekly transcribed debate discussion for client soft-skill discussion
  • among other weekly client advisory critical updates

Questions? Contact customer service: TaxFactsHelp@alm.com800-543-0874

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International Tax Risk Management, Data Analytics, and Technology – Team Based Case Studies – Apply Now for August Start

Posted by William Byrnes on July 6, 2020


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 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)

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: 

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Register for May 18th Start of Int’l Tax Risk Management (Data, Analytics & Technology) or FATCA/CRS/AEoI Compliance summer courses w/ Zoom

Posted by William Byrnes on April 27, 2020


Texas A&M International Tax Brochure: https://law.tamu.edu/distance-education/international-tax

  • Join the Texas A&M Aggie alumn network of 500,000+ strong to open doors (and appreciate SEC football).
  • 150+ current graduate enrollment for risk, tax risk, and wealth management curriculum.
  • Experience real-world case studies by industry leaders through an interdisciplinary approach to team learning.
  • Degree options for all tax professionals — lawyers (Master of Laws, LL.M.) and accountants, economists, financial professionals (Master of Jurisprudence, M.Jur.).

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!

SUMMER 2020 (May 18 through June 30) (register now)

FATCA, CRS, AEoI, Systems and Data3 credits (meet 8:00am Wednesday and 9am Sunday Central Daylight Dallas time zone)

  • Week 1. May 18: FATCA, CRS, and EU: nationality, residency, data sharing: Dr. Bruno Da Silva (Loyens & Loeff) and William Byrnes (TAMU).
  • Week 2. May 25: FATCA/CRS and the Asset Management Industry, intermediaries: Denise Hintzke (Deloitte)
  • 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)
  • Week 5. June 15: FATCA IGAs & CRS Risk Management Melissa Muhammad
  • Week 6. June 23: Financial Institutions Systems And Data: Haydon Perryman (Bank of America, UBS, Barclays, RBS and Lloyds)
  • Week 7 capstone for both Summer courses: “Tax Technology and the future of Tax Departments” Dr. Debora Correa Talutto

International Tax Risk Management I (Data, Analytics & Technology) 3 credits (meet Tuesday and Friday at 8:00am Central Daylight Dallas time zone)

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

FALL 2020 (Aug 23 through Nov 23) 3 credits (meet Wednesday and Sunday at 8am Central Daylight Dallas time zone)

Domestic Systems International Tax Risk Management

  • Week 1 Aug 23 maybe Brazil/Canda? (extractive) Oil & Gas ask Susana Bokobo, global tax policy director Repsol
  • Week 2 Aug 30 Mexico Aug 30 Mexico
  • Week 3 Sept 6 India (services)
  • Week 4 Sept 13 China (supply chain)
  • Week 5 Sept 20 Japan Dr. Maji Rhee (Waseda)
  • Week 6 Sept 27 Brazil

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 Niraja Srinivasan Pillar 1
  • 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

International Tax & Tax Treaties I: Residency Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Wednesday and Sunday 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 Low Tax Risk: OECD Pillar II, C.F.C., U.S. Tax Reform (GILTI, BEAT) 

International Tax & Tax Treaties II: Source Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Wednesday and Sunday 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
  • Capstone Nov 23: Groups Create Client Case Studies

SPRING 2021 (Jan 10 – April 26)

U.S. Tax Risk Management (Data, Analytics & Technology) 3 credits (Wednesday and Sunday at 8am Central Standard 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 

E.U. International Risk Management 3 credits (Wednesday and Sunday at 9am 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)
  • Week 6 April 11, 2021 ATAD, DAC 6, Abuse – Dr. Bruno da Silva
  • Capstone Week: Build a client case study, wrap up 

Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data (William Byrnes course material professor)

  • Week 1 January 13 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva William Byrnes
  • Week 2 Jan 20 CUP & Comparables  Dr. Lorraine Eden
  • Week 3 Jan 27 Cost Plus & Resale Minus  Dr. George Salis
  • Week 4 Feb 3: Comparable Profits Method & TNMM Dr. George Salis
  • Week 5 Feb 10 Profit Split Dr. George Salis
  • Week 6 Feb 17 Best Method Dr. Lorraine Eden 

Transfer Pricing Risk Management: Intangibles and Services (William Byrnes course material professor)

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International Tax Risk Management Summer Zoom Courses May 18 – July 3

Posted by William Byrnes on April 10, 2020


Want to speak with Admissions or read the brochure? information – click here

FATCA, CRS, AEoI, Systems and Data: 3 credits (Zoom class 8am Wednesday and 9am Sunday Central Daylight Dallas time zone)

  • Week 1. May 18: FATCA, CRS, and EU: nationality, residency, data sharing: Dr. Bruno Da Silva (Loyens & Loeff)
  • Week 2. May 25: FATCA/CRS and the Asset Management Industry, intermediaries: Denise Hintzke (Deloitte)
  • Week 3. June 1: FATCA Withholding Compliance, overlap with QI: Denise Hintzke (Deloitte)
  • Week 4. June 8: Documentation FATCA v CRS: Danielle Nishida (KPMG) / Laurie Hatten-Boyd (KPMG)
  • Week 5. June 15: FATCA IGAs & CRS Risk Management Danielle Nishida (KPMG) or Laurie Hatten-Boyd (KPMG)
  • Week 6. June 23: Financial Institutions Systems And Data: Haydon Perryman (Bank of America, UBS, Barclays, RBS and Lloyds)

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

  • Week 1. May 18: General tax risk management approach Dr. Knut Olsen
  • Week 2. May 25: BEPS: Dr. Bruno Da Silva (Loyens & Loeff).
  • Week 3. June 1: CbCR & Analytics David Deputy Vertex
  • Week 4. June 8: LOB / PPT / MLI: Dr. Bruno da Silva (Loyens & Loeff)
  • Week 5. June 15: Interest (thin cap, EBIDTA), Debt/Equity, Hybrids – TBD
  • Week 6. June 23: Future of Analytics & Technology from a Risk Management Perspective: Dr. Paula de Witte
  • Week 7 capstone for both Summer courses: “Tax Technology and the future of Tax Departments” Dr. Debora Correa Talutto

(Fall course) International Tax Risk Management II (Data, Analytics & Technology) 3 credits (meet Tuesday and Friday at 9am Central Daylight Dallas time zone) (tentative time)

  • Week 1 Oct 11 Manufacturing Supply Chain Tax Risk Niraja Srinivasan
  • Week 2 Oct 18 Manufacturing Value Chain Tax Risk Niraja Srinivasan
  • Week 3 Oct 25 Manufacturing & Customs Risk Niraja Srinivasan
  • Week 4 Nov 1 Tax of Patents / Technology, Dr. Brigitte Muehlmann 
  • Week 5 Nov 8 Tax Risk & Tax Technology, Dr. Brigitte Muehlmann
  • Week 6 Nov 15 Tax Risk & Tax Technology, Dr. Brigitte Muehlmann

FALL 2020 (Aug 23 through Nov 23) 3 credits (meet Tuesday and Friday at 9am Central Daylight Dallas time zone)

Domestic Tax Systems Risk Management

  • Week 1 Aug 23 Oil & Gas tax risk survey of country tax risk Susana Bokobo,
  • Week 2 Aug 30 Mexico Tax Risk
  • Week 3 Sept 6 India Tax Risk (services)
  • Week 4 Sept 13 China Tax Risk
  • Week 5 Sept 20 Japan Dr. Maji Rhee (Waseda) majirhee@waseda.jp
  • Week 6 Sept 27 Brazil Tax Risk

International Tax & Tax Treaties I: Residency Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Tuesday 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

International Tax & Tax Treaties II: Source Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Tuesday 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
  • Capstone Nov 23: Groups Create Client Case Studies

Why Texas A&M University School of Law? found out more by clicking here

  • Join the Aggie alumn network of 500,000+ strong that may open doors and help you elevate your career (and appreciate SEC football).
  • Experience real-world application through an interdisciplinary approach to teaching.
  • Degree options for all tax professionals — lawyers (Master of Laws, LL.M.) and accountants, economists, financial professionals (Master of Jurisprudence, M.Jur.).

Texas A&M, annual budget over $6 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 11th “Best Public Colleges” Money’s Best Colleges Report, 2019

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International Tax Risk Management case studies online Summer and Fall courses for 2020

Posted by William Byrnes on March 6, 2020


Want to join one of the case study teams for the international tax risk management courses taught live online, using Zoom, by industry’s recognized tax risk leaders and leading tax authors?  The courses are for tax attorneys, accountants, or economists and count toward the Texas A&M’s Master and LL.M. degrees in residence and online.

The class of a maximum of 18 students will be grouped into teams of 3 students each. The 6 teams meet using Zoom to prepare a weekly presentation to respond to a real-world post-BEPS client study. Then all teams meet twice together each week ‘in live session class’ via Zoom with the industry case study topic expert professor and the course professor, 9:00am – 10:30am Dallas Central time to discuss and present the case study solutions. Students are provided without charge the learning and textbook materials, videos with PPT, and podcasts, and granted access to a large online law & business/tax database library including Lexis, Bloomberg, IBFD, Kluwer/CCH, Thomson, BvD, S&P, among many other tax and financial data resources.

To apply for the international tax courses, contact Jeff Green, Graduate Programs Coordinator, T: +1 (817) 212-3866, E: jeffgreen@law.tamu.edu or contact David Dye, Assistant Dean of Graduate Programs, T (817) 212-3954, E: ddye@law.tamu.edu. Texas A&M Admissions website: https://law.tamu.edu/distance-education/international-tax  (applications require university transcripts delivered by May 15).

Strength of the Aggie Network: Texas A&M, annual budget over $6 billion (FY2020), is the largest U.S. public university, with the renown Aggie former students network exceeding 500,000 around the world, Texas A&M is 1 of only 60 accredited U.S. universities of the American Association of Universities (R1: Doctoral Universities – Highest Research Activity) and 1 of only 17 U.S. universities that hold the triple U.S. federal grant of Land, Sea, and Space!

 

SUMMER 2020 (May 18 through June 30)

FATCA, CRS, AEoI, Systems and Data: 3 credits (meet Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Week 1. May 18: FATCA, CRS, and EU: nationality, residency, data sharing: Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU).

Week 2. May 25: FATCA/CRS and the Asset Management Industry, intermediaries: Denise Hintzke (Deloitte)

Week 3. June 1: FATCA Withholding Compliance, overlap with QI: Denise Hintzke (Deloitte)

Week 4. June 8: Documentation FATCA v CRS: Danielle Nishida (KPMG) / Laurie Hatten-Boyd (KPMG)

Week 5. June 15: Danielle Nishida (KPMG) or Laurie Hatten-Boyd (KPMG)

Week 6. June 23: Financial Institutions Systems And Data: Haydon Perryman (Bank of America, UBS, Barclays, RBS and Lloyds) 

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

Week 1. May 18: BEPS: Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU).

Week 2. May 25: Interest (thin cap, EBIDTA):

Week 3. June 1: CbCR & Analytics David Deputy, Vertex

Week 4. June 8: LOB / PPT / MLI: Dr. Bruno da Silva (Loyens & Loeff)

Week 5. June 15: General tax risk management approach Dr. Knut Olsen

Week 6. June 23: Future of Analytics & Technology from a Risk Management Perspective: Dr. Paula de Witte 

FALL 2020 (Aug 23 through Nov 23) 3 credits (meet Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Domestic Tax Systems Risk Management

Week 1 Aug 23 Canada (extractive)

Week 2 Aug 30 Mexico (manufacturing)

Week 3 Sept 6 India (services)

Week 4 Sept 13 China (supply chain)

Week 5 Sept 20 Japan Dr. Maji Rhee (Waseda) (comps and secret comps)

Week 6 Sept 27 UK (financial services) 

International Tax Risk Management II (Data, Analytics & Technology) 3 credits (meet Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Week 1 Oct 11 Technology industry (Dell) Pillar 2 – CFC, GILTI, related

Week 2 Oct 18 Manufacture

Week 3 Oct 25 Oil & Gas

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   

International Tax & Tax Treaties I: Residency Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Wednesday and Sunday at 9am 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 Pillar 1 And 2 (Taxation of Digital; Min Effective Tax)

 International Tax & Tax Treaties II: Source Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits (meet Wednesday and Sunday at 9am Central Daylight Dallas time zone)

Week 1 Oct 11 Tax of Business Income

Week 2 Oct 18 Tax of Investment Income

Week 3: Oct 25 Taxation of Services and Employment Income

Week 4: Nov 1 Double Taxation and Tax Credits (Daylight time ends, Wednesday and Sunday at 8am Central Standard Dallas time zone)

Week 5: Nov 8 Tax Accounting

Week 6: Nov 15 Introduction to Management of Tax and Data

Capstone Nov 23: Groups Create Client Case Studies

SPRING 2021 (Jan 10 – April 26)

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

Week 1 January 10, 2021 Outbound / FDII Melissa Muhammad

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 

E.U. International Risk Management 3 credits (Wednesday and Sunday at 9am 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)

Week 6 April 11, 2021 ATAD, DAC 6, Abuse – Dr. Bruno da Silva

Capstone Week: Build a client case study, wrap up 

Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data (William Byrnes course material professor)

Week 1 January 13 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva & William Byrnes

Week 2 Jan 20 CUP & Comparables  Dr. Lorraine Eden

Week 3 Jan 27 Cost Plus & Resale Minus  Dr. George Salis

Week 4 Feb 3: Comparable Profits Method & TNMM Dr. George Salis

Week 5 Feb 10 Profit Split Dr. George Salis

Week 6 Feb 17 Best Method Dr. Lorraine Eden 

Transfer Pricing Risk Management: Intangibles and Services (William Byrnes course material professor)

Week 1 March 2 Intangibles Royalty Rates CUT and CPM  Dr. Debora Correa Talutto

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

Capstone Hand-On Week with Financial databases April 20 – 26: Thomson OneSource, BvD (Moodys), and CrossBorder AI Solutions Dr. Debora Correa Talutto & William Byrnes

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Transfer Pricing case studies online course Jan 13 – Apr 19, 2020

Posted by William Byrnes on December 18, 2019


Last chance to join one of the case study teams for TRANSFER PRICING taught live online, using Zoom, by Dr. Lorraine Eden, Prof. William Byrnes, and many industry experts… The courses are for tax attorneys, accountants, or economists and count toward the Texas A&M’s INTERNATIONAL TAX Master degree (taught online).

The class of a maximum of 18 students will be grouped into teams of 3 students each. The 6 teams meet using Zoom to prepare a weekly TP Aggiespresentation to respond to a real-world post-BEPS client study. Then all teams meet together online via Zoom twice each week at 8:00am Dallas time Wednesdays and Sundays to discuss and present the case study solutions. Students are provided without charge textbook materials, videos with PPT, and podcasts, and granted access to a large online law & business database library including Lexis, Bloomberg, IBFD, Kluwer/CCH, Thomson, among many other tax resources.

To apply for the transfer pricing courses and international tax courses, contact Jeff Green, Graduate Programs Coordinator, T: +1 (817) 212-3866, E: jeffgreen@law.tamu.edu or contact David Dye, Assistant Dean of Graduate Programs, T (817) 212-3954, E: ddye@law.tamu.edu. Texas A&M Admissions website: https://law.tamu.edu/distance-education/international-tax  (applications and previous university transcripts must be received by Admissions before Wednesday, January 8th at 5pm Texas time). Note that the university is closed for the holidays from Dec. 20 until Jan. 2, 2020.

 

 

 

 

Course I: Tangibles, Methods

  • Week 1 January 13 Arm’s Length Standard (v Formulary Approach) case study
  • Week 2 Jan 20 CUP & Comparables case study
  • Week 3 Jan 27 Cost Plus & Resale Minus case study
  • Week 4 Feb 3: Comparable Profits Method & TNMM case study
  • Week 5 Feb 10 Profit Split case study
  • Week 6 Feb 17 Best Method case study

Course II: Intangibles, Services

  • Week 1 March 2 Intangibles Royalty Rates CUT and CPM case study
  • Week 2 March 16: CSA Intangibles Buy In/Out case study
  • Week 3 March 23: Digital Business Unitary Apportionment case study
  • Week 4 March 30 Digital Value Chain, Internet of Things case study
  • Week 5 April 6 U.S. v OECD v UN Manual case study Extractive Industries, Financing
  • Week 6 April 13 Restructuring the Business, Services case study

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Transfer Pricing case studies online course Jan 13 – Apr 19 (live Zoom based classes, small team groups)

Posted by William Byrnes on December 13, 2019


Interested to join one of the case study teams for TRANSFER PRICING taught live online, using Zoom, by Dr. Lorraine Eden, Prof. William Byrnes, and many industry experts January 13 – April 19. The courses are for tax attorneys, accountants, or economists and count toward the Texas A&M INTERNATIONAL TAX online Master curriculum.

The class is divided into teams of 3 or 4 students, each team meets internally using Zoom to prepare a team response and presentation for a real-world post-BEPS client study. Then the entire class meets twice each week: (A) on Wednesdays to discuss the case study with the Subject Matter Expert and Prof. William Byrnes, and (B) on Sundays each team presents interactively their positions and solutions in a friendly rivalry against the other teams, facilitated by William Byrnes and the Subject Matter Expert professor.  Students are provided textbook materials, videos with PPT, and podcasts, while learning to use a robust online law & business database library. The weekly lead Subject Matter Experts listed below and several more will be joining to explain specific tools and issues.

To apply for the transfer pricing courses and international tax courses, contact Jeff Green, Graduate Programs Coordinator, T: +1 (817) 212-3866, E: jeffgreen@law.tamu.edu or contact David Dye, Assistant Dean of Graduate Programs, T (817) 212-3954, E: ddye@law.tamu.edu. Texas A&M Admissions website: https://law.tamu.edu/distance-education/international-tax  (applications with all previous degree academic transcripts must be received by Admissions before Wednesday January 8th at 5pm Texas time)

Texas A&M Law offers the premier online program in international tax with a multidisciplinary, risk-management-focused approach. Our TP Aggiesunique, industry-based online curriculum is vetted by and focuses on the needs of multinational corporations, large firms, and governments. Though one of the largest U.S. public universities of 70,000 students and an annual budget exceeding $6 billion (FY2020), Texas A&M’s international tax curriculum offers small class sizes (maximum 30) to ensure personal faculty and in-class engagement. Smaller class sizes also allow stronger engagement and connections to develop among classmates who learn from each other’s corporate experiences.

  • Class meeting time is 60  – 120 minutes each Wednesday and Sunday at Central (Texas) time 08:00 (am) (i.e. 15:00 Paris; 18:00 Dubai; 22:00 Shanghai). The sessions are normally recorded if students are unable to attend because of client commitments or must sign off early.
            Capstone Week April 20 – 26: students teams build case studies that winning teams can present next year in the courses

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Transfer Pricing case studies online course Jan 13 – Apr 19 (live Zoom based classes, small team groups)

Posted by William Byrnes on November 26, 2019


Interested to join one of the case study teams for TRANSFER PRICING taught live online, using Zoom, by Dr. Lorraine Eden, Prof. William Byrnes, and industry experts January 13 – April 19. The courses are for tax attorneys, accountants, or economists and count toward the Texas A&M INTERNATIONAL TAX online Master curriculum. The class meets each week to discuss the real-world post-BEPS client studies and then again weekly the teams present their positions and solutions.  During the week the teams meet internally via Zoom and study provided materials, videos and audio casts based on provided PPTs, while using a robust online law & business database library.  For more information about how to apply, contact Texas A&M Admissions https://info.law.tamu.edu/international-tax

Texas A&M Law offers the premier online program in international tax with a multidisciplinary, risk-management-focused approach. Our TP Aggiesunique, industry-based online curriculum is vetted by and focuses on the needs of multinational corporations, large firms, and governments. Though one of the largest U.S. public universities of 70,000 students and an annual budget exceeding $6 billion (FY2020), Texas A&M’s international tax curriculum offers small class sizes (maximum 30) to ensure personal faculty and in-class engagement. Smaller class sizes also allow stronger engagement and connections to develop among classmates who learn from each other’s corporate experiences.

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Transfer Pricing case studies based course Jan 13 – Apr 20 (Zoom based, small team groups)

Posted by William Byrnes on November 7, 2019


Nine seats remain for the Spring (4 teams of 3 students each) to join the current 4 teams January 13 – April 20 semester for TRANSFER PRICING taught by Dr. Lorraine Eden, Prof. William Byrnes, TP Aggiesand several industry experts. The courses count toward the INTERNATIONAL TAX online Master curriculum of Texas A&M for tax attorneys, accountants, and economists. Taught live twice weekly using Zoom involving teams working to design positions and solutions for real-world post-BEPS client studies each week, supported by originally authored materials, videos and audio casts, PPTs, and a robust online law & business database library.  For more information, contact Texas A&M Admissions https://info.law.tamu.edu/international-tax

Texas A&M Law offers the premier online program in international tax with a multidisciplinary, risk-management-focused approach. Our unique, industry-based online curriculum is vetted by and focuses on the needs of multinational corporations, large firms and governments. A degree from Texas A&M University, a Tier-1 research institution and one of the largest U.S. public universities, is recognized worldwide. Texas A&M’s online International Tax Program is specifically designed for tax professionals, both lawyers and non-lawyers, whose careers demand an understanding of international taxation and related issues.  For more information, contact Texas A&M Admissions https://info.law.tamu.edu/international-tax

The International Tax graduate program is an online, 24 or 30 credit hour graduate degree that can be completed in less than two years. The degree program offers a competitive advantage to any tax professional, including lawyers, accountants, finance executives and economists, that advises multinational clients on business and investment, or that works within a tax (risk management) department.

    • Industry-Responsive Curriculum:  A tax-risk management approach with a focus on tax data management and risk analysis based on the results of in-depth industry research.
      • Hanover Research, on behalf of Texas A&M, interviewed one-on-one and then validated by anonymous survey over 100 tax executives from multinational corporations, large firms and government. As a result, the program is designed with faculty and degree candidates that are multidisciplinary, including both tax lawyers and non-lawyer tax professionals, engaged together in teams.
    • Incredible Student Experience:  Texas A&M law offers small class sizes to ensure each student gets personal attention. These small class sizes allow ​you to forge strong connections with your classmates and to learn from each other’s experiences.
    • Faculty Expertise & Leadership:  The curriculum has been developed and is led by Professor William Byrnes, an international tax authority and globally recognized online education pioneer focused on student outcomes. The program’s faculty are multidisciplinary (e.g. lawyers, economists, accountants, data scientists) and include renowned authors, academics, tax executives of multinational corporations, and tax advisors from large firms.

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The Battle to Legalize Marijuana Comes Down to Tax Deductions and the 16th Amendment

Posted by William Byrnes on November 6, 2019


Every day I comb through my Law360 Tax Authority list of articles in order to update one of my tax treatises.  I found a really interesting one though today for my Money Laundering treatise.  It’s about fitting an elephant through a keyhole.  With enough pressure, it can be done, but by breaking down the entire door.  The case is Northern California Small Business Assistants Inc. v. Commissioner, 153 T.C. No. 4 (Oct. 23, 2019).  The Law360 Tax Authority analysis is here: https://www.law360.com/articles/1215134/tax-court-decision-may-open-up-new-challenges-to-280e

My commentary this week… (well, it will be for a debate in my Spring Fed Income Tax course actually)

Of course, it’s not a violation of 8th because not a penalty, albeit I appreciate the (losing) argument.  Yet, at this stage, cross-aisle agree both federal Cannabis-leaf-hempand state, marijuana, at least at defined dosages, it is more like Valium on Schedule IV then Vicodin Schedule II.  The Schedules allow for dosage amounts. Only ardent prohibitionists I think (I am no expert) want the Schedule I classification to remain.  I am sure state leaders, the financial industry (because of the AML provisions of the BSA), the IRS, and the AG industry want it reduced to at least Schedule II but preferably Schedule IV where it belongs.  Or break it up by THC levels into Sch II, III, and IV.

But I think that the DEA is the real problem. I do not understand why the DEA will not remove marijuana from the blacklist (Schedule I) unless the DEA needs it on Schedule I to maintain its significant funding for global marijuana crop eradication programs because govt agencies never shrink themselves by giving up jurisdiction or budget. But I do not believe that the FDA, HHS, et al who inform the DEA want to keep it at Schedule I.  Read the DEA’s current policy regarding CBD and THC-Cannabis.  The medical pharmacological evidence is building of the benefits for various ailments, see the 2017 National Institutes of Health meta analysis (Medicinal Cannabis: History, Pharmacology, And Implications for the Acute Care Setting).  All pharma has side effects so the fact that some participants who ingested the THC Cannabis (“got high”) reported being dizzy is very mild (‘don’t operate heavy machinery or drive’ warning labels mandatory). Prolonged and heavy use of any pharma, any drug like caffeine (of which I have much experience, but not willing to kick the habit yet) and alcohol, is probably going to be harmful to very harmful to just out-right early death.  I am not saying something new – everyone in the debate already knows all the arguments for and against.  So it’s either the teetotaler lobby, the DEA not wanting to give up ‘the war against marijuana”, or a combination, keeping marijuana on Schedule I.

So lots of pressure on Treasury to fix two insurmountable issues to marijuana state-licensed businesses from being federally legit and compliant. The BSA problem for AML compliance (keeps this a cash business) and the IRC 280E problem (makes marijuana industry a federal tax evader or unprofitable because effective rates of taxation of state and federal are in many cases greater than 100% of net income).  And Treasury wants to fix it.  But its hands are technically tied because the DEA will not delist marijuana from Schedule I.  That forces 280E and AML rules to kick in.  I’d be happy for Treasury to ignore the law but it’s too dangerous for Treasury or any agency to pick and choose what laws to adhere to. Of course, the discretion of enforcement is a totally different issue.

The AML issue Treasury issued, albeit the former prohibitionist AG basically said DOJ is not playing ball, a soft guidance explaining to banks how to distinguish good and bad marijuana dollars (the Marijuana SAR guidance). (See marijuana SAR results for 2018) For 280E though, Treasury would need to tell the IRS to ignore 280E marijuana stated licensed businesses fraudulent filed returns to circumvent the prohibition of deductions.  It would be really hard to administer the audits.

If Treasury cannot do it, but wants to do it, that leaves the Tax Court.  The Tax Court judges have over the past two years have concluded that marijuana should be removed from Schedule I so that 280E is not an issue.  In this case, once again the conclusion is:

“Congress, rather than this Court, is the proper body to redress petitioner’s grievances. We are constrained by the law, and Congress has not carved out an exception in section 280E for businesses that operate lawfully under State law.”

It’s only doing so because the IRS Counsel (must I think) express this in arguments to the Court, begging the Court for a way out of this mess. So the Tax Court has written that Congress or an agency needs to fix the problem.  It hasn’t been fixed.   And then this case where a powerful voice on the Tax Court said to the DEA and Congress: ‘do not force us to rectify the problem because you are not going to like the theoretical hoop we must jump through to do it.’

So, the theoretical argument that could gain some traction about the denial of all deductions by 280E is that it imposes the tax rate (say 37%) on revenue which may violate the intention of the 16th Amendment.  This is what Gustafon is musing about at page 23. I agree.

At page 26 the point is driven home (pun coming..):

Very different would be an attempt by Congress to tax gross proceeds from the sale of a capital asset, without allowing a taxpayer to account for his “basis” in the property in calculating his taxable gain.”

So imagine Congress imposes the ordinary tax rate on the sale price of an individual taxpayer’s sale of the home.  Say 37% on $500,000.  Taxpayer not allowed the basis reduction of the acquisition cost of $450,000 three years ago.  TP owes $185,000 tax (and also the additional 3.8% Net Investment Income Tax), on the $50,000 – expenses of the transaction gain.  Of course, this is absurd because property requires financing and the remaining would be less than any mortgage secured loan.  Same scenario but now shares in Apple bought at $220 last year by our home owing taxpayer and 13 months later sold for $250.  Economic collapse.  TP rebellion.  Not a pretty civil scenario.

Well, 280E does not deny deductions for the cost of goods (of the narcotics like marijuana or heroin – I do not think marijuana should be a black-listed scheduled narcotic).  But why not?  Because, simply put, an ‘income’ tax on business ‘income’ should be imposed on the ‘income’ and not on the revenue which is not a business’ income.  A tax imposed on a business revenue is something other than an ‘income tax’.  Excise tax maybe, but not an income tax.  See Judge Gustafson explain this at page 26-27.

Likewise, a congressional attempt to tax the gross receipts of a business engaged in sales should fail. A taxpayer who purchased 100 widgets at a cost of $10 each and sold them at a price of $9 each would have gross receipts or sales of $900, which after being reduced by the “cost of goods sold” (“COGS”) of $1,000 (analogous to basis in the Blackacre example) would yield a loss of $100. Given that obvious loss, Congress could not tax the gross receipts of $900 as if it were “income”. Rather, as the Court of Appeals for the Tenth Circuit has explained: “To ensure taxation of income rather than sales, the ‘cost of goods sold’ is a mandatory exclusion from the calculation of a taxpayer’s gross income.””

Can Congress levy a tax on revenue under the 16th?  We know the answer is no because that is why COG is allowed to be above the line to derive an income, and then 280E applies.  Well settled.  See page 27.

The taxation of “income” must take account of the “basis” in a capital asset and of the COGS of inventory–not merely as an exercise of “legislative grace” but as mandatory under the Sixteenth Amendment of the Constitution.”

So some expenses are allowed being COG, and other, operating expenses, not allowed.  Already 280E is in a quagmire of discriminating between good and bad expenses to fit into the 16th.  Thus, the Tax Court could force a bushel of marijuana through a 280E keyhole using the pressure of the 16th Amend if it must to deal with this situation.  Gustafson’s push through the keyhole is the second part of his sentence highlighted below at page 29.

“Congress taxes something other than a taxpayer’s “income” when it taxes gross receipts without accounting for basis or COGS--and, I would hold, when it taxes gross receipts without accounting for the ordinary and necessary expenses that are incurred in the course of business and must be paid before one can be said to have gain.”

The argument requires stretching the keyhole with a lot of 16th Amend pressure (though I personally quite like the 16th argument) and Appellate Circuits may want to keep the keyhole rather small and deflate that pressure.  But I think that the 1st, 9th, and 10th judges have to live in states where education or other government funding is significantly helped by the state-legal licensed marijuana industry.  Judges look at neighbor farmers who cannot sell to China about to go belly up with their grains and soybean – where marijuana can save the farm.  I have no litigation or controversy experience but I imagine some Appellate judges know these situations from reading or table talk.

So if the stretch of the 280E keyhole is not totally implausible by using the 16th Amend, a panel may just agree to send a message like the Tax Court to the DEA and failing that, Congress.  Anyway, the Supremes can sort out the ramifications of using the 16th to stretch the 280E keyhole.  And by that time, maybe the DEA did what the public pressure wants it to do, and is the right thing to do based on medical evidence being generated, move marijuana, based on amount of THC, to the relevant schedules of II through IV.

Anyway, my take on this case.  Look forward to our Spring debate.

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Seeking inaugural cohort of tax professionals to pilot Texas A&M’s International Tax online curriculum starting August 26, 2019

Posted by William Byrnes on July 29, 2019


Texas A&M University School of Law will launch August 26, 2019 its International Tax online curriculum for graduate degree candidates. Admissions is open for the inaugural cohort of degree candidates to pilot the launch of the Fall semester introductory courses of international taxation and tax treaties.

How do I apply for the inaugural cohort? Only for this inaugural cohort, completed applications may be submitted directly, via the below-expedited process, to the law school’s admission office until noon central daylight time (CDT – Dallas) on August 22, 2019.   A completed Fall application must include four items:

(1) the completed and signed law school application (application fees and letters of recommendation are waived for Fall 2019 international tax);

(2) statement of interest for the international tax program that includes mention of prior tax or related experience.

(3) resume/CV reflecting at least three years of employment as a tax advisor or five years employment in a related field; and

(4) an official transcript from the highest academic degree awarded by an accredited University sent to Texas A&M University: Official electronic transcripts can be sent to law-admissions@law.tamu.edu  FedEx, UPS, DHL express mail can be sent to Attn: Office of Graduate Admissions 1515 Commerce Street Fort Worth, TX 76102-6509

To apply for the inaugural cohort opportunity, contact Jeff Green, Graduate Programs Coordinator, T: +1 (817) 212-3866, E: jeffgreen@law.tamu.edu or contact David Dye, Assistant Dean of Graduate Programs, T (817) 212-3954, E: ddye@law.tamu.edu. Texas A&M Admissions website: https://law.tamu.edu/distance-education/international-tax

What is the proposed curriculum of 12 international tax courses?

International Taxation & Treaties I (3 credits)                  International Taxation & Treaties II (3 credits)

Transfer Pricing I (3 credits)                                          Transfer Pricing II (3 credits)

Tax Risk Management (3 credits)                                  FATCA & CRS (3 credits)

International Tax Planning (3 credits)                             Country Tax Systems (3 credits)

U.S. Int’l Tax (3 credits)                                                 EU Taxation (3 credits)

VAT/GST/Sales (3 credits)                                            Customs & Excises (3 credits)

Ethics in Decision Making (1 credit required to graduate)

What distinguishes Texas A&M’s International Tax curriculum?

Since the original 1994 curriculum focus on tax risk management and methodology, the curriculum and the program operational structure continue to evolve based on in-depth industry research. “The central function of the tax office has evolved from strategy and planning into risk management”, says William Byrnes, professor of law and associate dean at Texas A&M University. “This evolution has been accelerated by trends — primarily globalization, transparency and regulatory reform — and by the OECD (through the project on Base Erosion and Profit Shifting, or BEPS), the United States (through the Foreign Account Tax Compliance Act) and the European Union.”

In 2019, Hanover Research on behalf of Texas A&M undertook an extensive long-form survey, including interviews, of 146 tax executives about the needs and value-added of Texas A&M’s new international tax curriculum. The surveys 2019 tax professionals included: 29% U.S. and 71% foreign resident. Half the participants were tax professionals of AmLaw 100 firms (27%) or of Big 4 accounting (21%). The other half of participants were tax professionals of large multinational tax departments in the following industries: Finance / Banking / Insurance; Consulting; Business / Professional Services; Computers (Hardware, Desktop Software); Telecommunications; Aerospace / Aviation / Automotive; Healthcare / Medical; Manufacturing; Food Service; Internet; Mining; Pharmaceutical / Chemical; Real Estate; and Transportation / Distribution. Four percent of survey participants were executive-level government tax authority staff.

Besides the actual design of the course curriculum, two interesting outcomes from the industry interviews are:

  • The faculty and graduate degree candidates must be multidisciplinary, including both tax lawyers and non-lawyer tax professionals (e.g. accountants, finance executives, and economists) engaged together in learning teams with practical case studies and projects that are “applicable in a real-world context”.
  • The curriculum must include the perspectives of tax mitigation and of tax-risk management with exposure to state-of-the-industry data analytics.

In its Tax Insights magazine that is distributed globally to clients, the Big 4 firm EY stated: “Texas A&M University is among the pioneers of change in tax education”.

Texas A&M professor William Byrnes explains: “A risk management approach to tax means that the new model will by definition be multidisciplinary. Financial and managerial accounting– and law– will still be important, of course. But students will also need new “hard” skills involving big data and communications technologies and “soft” skills geared to working in multicultural settings both at home and abroad.” Says Byrnes, “You don’t want to have people who are living in the ‘Stone Age’ (pre-2015) trying to work in a 2016-onward world.” 

What is the proposed course schedule during an academic year?

Fall 2019 Part A (6 week term)                                    Fall 2019 Part B (6 week term)     

International Taxation & Treaties I                                  International Taxation & Treaties II 

Spring 2020 Part A (6 week term)                              Spring 2020 Part B (6 week term)

Transfer Pricing I                                                             Transfer Pricing II

Summer 2020 concurrent 6 week term

Tax Risk Management & Data Analytics             FATCA & CRS

Fall 2020 Part A                                                           Fall 2020 Part B

International Tax Planning                                             Country Tax Systems

International Taxation & Treaties I                                  International Taxation & Treaties II

Spring 2021 Part A                                                      Spring 2021 Part B

U.S. Int’l Tax                                                                 EU Taxation

Transfer Pricing I                                                           Transfer Pricing II

Summer 2021 concurrent term

VAT/GST/Sales             Customs & Excises

Tax Risk Management               FATCA & CRS

When are the semesters?

Fall:                 August 26 until December 14, 2019

Spring:             January 9 until April 30, 2020

Summer:          May 18 until July 11, 2020

Who is leading and creating this International Tax curriculum?

The International Tax curriculum has been developed and is led by Professor William Byrnes (Texas A&M University Law).  In 1994, Professor William Byrnes founded the first international tax program leveraging online education and in 1998 founded the first online international tax program to be acquiesced by the American Bar Association and the Southern Association of Colleges and Schools.  He is recognized globally as an online education pioneer focused on learner outcomes and best practices leveraging state of the art educational technology.  William Byrnes is also an international tax authority as LexisNexis’ leading published author of nine international tax treatises and compendium, annually updated, and a 10 volume service published by Wolters Kluwer.  His LinkedIn group International Tax Planning Professionals has over 25,000 members and is the largest international tax network on LinkedIn.

If you want to ask questions about the curriculum or how the online courses are as effective as residential ones, reach out to Professor William Byrnes at williambyrnes@law.tamu.edu.

How much time per week does a course require?

Each course unfolds over six weeks, designed to require 15 to 20 hours of input each week. This weekly input includes reviewing materials, listening to podcasts, watching video content, participating in discussion forums, engaging in live class sessions, and working with classmates on team-based learning projects. Working with the colleague groups on real-world case studies is critical to the educational experience.  Potential applicants must have available three to five hours per week to spend developing and working with colleagues on group case studies using communications technologies like Zoom video.

What is the title of this graduate degree?

For lawyers, it is a Master of Laws (LL.M.) and for accountants, tax professionals and economists, it is a Master of Jurisprudence (M.J.).  The degree is awarded by Texas A&M University via the School of Law. Completion of a curriculum, which is like a ‘major’ for university studies, is also recognized with a frameable certificate issued by the School of Law.

What are the minimum requirements of the application for each degree?

  • All applicants must have previous domestic tax or accounting professional experience reflected on the CV of work experience.
  • The Master of Laws (LL.M.) is awarded to successful graduates who hold a law degree from a law school or faculty of law that is accredited by the American Bar Association or if a foreign law degree then accredited by a governmental accreditation body and that allows the graduate eligibility for that country’s practice of law.
  • The Master of Jurisprudence (M.J.) is awarded to all other successful graduates. Applicants for the Master of Jurisprudence must hold a prior degree from an accredited academic institution in business, accounting, finance, economics, or related business field.

What are the program requirements to graduate?

The Master of Laws candidates must complete at least 24 credits to be eligible to graduate.  The Master of Jurisprudence candidates must complete at least 30 credits to be eligible to graduate.

All candidates must complete the Ethics in Decision Making course to be eligible to graduate, which presents networking opportunities with candidates of the Risk management and Wealth Management curricula. Master of Jurisprudence candidates must also complete an Introduction to U.S. Law course which will include networking among all law graduate curricula.

Candidates must complete at least six courses specific to a curriculum in order to be eligible for a degree. Without permission, candidates are allowed to enroll in up to two courses from another curriculum.

How many months to graduate?

Normally, candidates will enroll in two courses during Fall and Spring semester, focusing on one course each term (Fall and Spring have two terms of six weeks each).  Candidates may enroll in one or two courses for the Summer semester, which is only one six-week term.  Thus, most candidates will reach eligibility to graduate within two years.  Candidates have the flexibility as to how many or few courses to enroll each term, subject to university graduate program rules. Candidates may complete the program in one year to as long as four years.  Each course in a curriculum is offered once per year.

Are these degrees eligible for the Aggie Ring and membership in the Texas A&M Former Student Network (Texas A&M alumni)?

Yes, all international tax graduates will become a member of the Texas A&M family.  Texas A&M is renown for the loyalty and engagement among its former students within the Texas Aggie clubs established throughout the world. Texas A&M has graduated over 500,000 “Aggies” who are eligible to wear the Texas A&M ring to identify each other throughout the world. See https://www.aggienetwork.com/

Will there be on-campus opportunities?

Yes.  Graduation, with on-campus activities hosted at the law school, is May 1, 2020.  October 24-25, 2019 is a networking conference of the risk, wealth, and international tax graduate students piggybacking on Texas A&M’s Financial Planning conference: Thursday night networking banquet and Friday conference activities. See https://financialplanning.tamu.edu/events/conference/  Saturday, October 26, 2019 is a Texas A&M football game at the on-campus Kyle stadium that two years ago underwent a $485 million renovation. The graduate program office has inquired about a block of tickets in the same section for students interested in purchasing a ticket and staying over for the game.  Texas A&M football games are sold out with a capacity of over 100,000 seats and thus, Friday night hotel reservations in College Station should be made ASAP.  Other opportunities will be announced during the program year.

What is Texas A&M University?

Texas A&M, the second largest U.S. public university, is one of the only 60 accredited U.S. members of the American Association of Universities (R1: Doctoral Universities – Highest Research Activity), and one of the only 17 U.S. universities that hold a triple U.S. federal designation (Land, Sea, and Space).  As one of the world’s leading research institutions, Texas A&M is at the forefront in making significant contributions to scholarship and discovery: research conducted in fiscal year 2017 at Texas A&M represented an annual expenditure of more than $900 million.  The Texas A&M University system’s operating budget exceeds $4.6 billion and Texas A&M’s combined endowments are 7th largest among universities in the world.

Texas A&M is ranked 1st among national public universities for a superior education at an affordable cost (Fiske, 2018); ranked 1st of Texas public universities for best value (Money, 2018); and ranked 1st in nation for most graduates serving as CEOs of Fortune 500 companies (Fortune, 2019).  During the program, a candidate learns Texas A&M’s traditions and six core values that are grounded in its history as one of the six U.S. senior military colleges: Loyalty, Integrity, Excellence, Leadership, Respect, and Selfless Service.

Which government and professional organizations accredit Texas A&M University?

For the complete list, see https://www.tamu.edu/statements/accreditation.html

What are the other curricula’s courses that are available to international tax candidates? 

Risk Curriculum                                              Wealth Curriculum

Enterprise Risk & Data Analytics                        Taxation of Business Associations

Information Security Management Systems        Securities Regulations

Counter-Terrorism Risk Management                 Financial & Portfolio Management

Cybersecurity                                                   Income Tax Financial Planning

Anti-Money Laundering & Bank                          Principles of Wealth Management

Principles of Risk Management                          Estate Planning, Insurance, and Annuities

Foreign Corrupt Practices Act                            Advanced Wealth Management

Fiduciary & Risk Management                            Non-Profit & Fiduciary Administration

White-Collar Crime                                            Retirement & Benefits

Legal Risk Management                                    Insurance Law (& Alternative Risk Transfer)

Financial Innovations

What is the tuition? Normal Texas A&M University tuition and available financial aid applies after the Fall term and is available at https://tuition.tamu.edu/ Texas A&M University is a public university of the state of Texas and is ranked 1st among public universities for its superior education at an affordable cost (Fiske, 2018) and ranked 1st of Texas public universities for best value (Money, 2018). 

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TEXAS A&M REACHES MILESTONE: EXPANDS ITS NETWORK TO 500,000+ AT GRADUATION

Posted by William Byrnes on May 3, 2019


Commencement ceremonies will be held May 3 in Fort Worth for Texas A&M University School of Law for 17​4 graduates. The day will include a Law School Aggie Ring ceremony and a Military Cord ceremony prior to the hooding ceremony.

The school’s first Masters of Jurisprudence (M.Jur.) ​diplomas will be awarded along with Masters of Law (LL.M.) honors. Graduates walking across the stage are students who earned their ​graduate degrees in ​risk ​management or ​wealth management via Texas A&M Law’s innovative online program.

This May, Texas A&M University will surpass 500,000 former students and record more than 500,000 degrees granted since its opening in the fall of 1876, according to Texas A&M Today. Texas A&M University will award a record 10,767 degrees at 15 commencement ceremonies across multiple campuses.

“These milestones are reflective of our commitment to our land-grant mission to bring higher education to all who seek it, to develop leaders of character and to pursue excellence in teaching, research and service,” Texas A&M University President Michael K. Young said. “Congratulations to the Class of 2019 for being part of this historic moment, and thank you to each and every Aggie who came before for providing the foundation upon which we will continue to build.”

“This milestone is a testament to the unique and unparalleled education and experience provided by Texas A&M. As we also celebrate our 140th year of service and support to Texas A&M, I know the 11 Aggies who created our organization in 1879 would be proud to see the difference 500,000 former students have made on Texas A&M and our world,” The Association of Former Students President and CEO Porter S. Garner III said.

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Texas A&M University Law is seeking to hire two new admission department team members

Posted by William Byrnes on October 16, 2015


The two new positions and application procedures are:

1. https://jobpath.tamu.edu/postings/89638

2. https://jobpath.tamu.edu/postings/88388

Please pass on these positions to potential interested persons.

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Texas A&M University School of Law Hires 12 New Faculty & Expands Programs

Posted by William Byrnes on September 23, 2015


Texas A&M University School of Law is quickly distinguishing itself as an institution to watch.

At a time when most schools are cutting back, Texas A&M University has made an unparalleled investment in the future of legal education for Texas, the nation and beyond by attracting an unprecedented 12 new faculty members for its School of Law located inFort Worth.

TAMU-Law-lockup-whiteFive of the new faculty focus on intellectual property issues, adding strength to the school’s Center for Law and Intellectual Property and building on A&M’s strong reputation in engineering and life sciences. These hires cover all aspects of intellectual property, including patents, copyrights, trademarks, and trade secrets. Together with two existing scholars in the field, A&M Law is now in contention to have one of the country’s top intellectual property law programs.

“This extensive concentration of intellectual property faculty offers students comprehensive coverage, allowing them to develop specialized training based on their individual interests and career paths,” said intellectual property expert and incoming professorPeter Yu. “Our newly expanded program offers an unparalleled focus and makes A&M Law immediately stand out in the intellectual property field.”

Among A&M Law’s seven additional hires are thought leaders with strong backgrounds in legal ethics, commercial law, legal writing, law and economics, tax and international law. They include the newly appointed President of Texas A&M University, Michael K. Young, whose two decades as a legal scholar and dean at Columbia Law included the development of internationally recognized programs in Japanese and Korean legal studies and authorship of numerous briefs, articles and books on U.S. trade law and policy.  Given his leadership, including presidency at two leading universities and service, it is fitting that he will hold tenure in both Texas A&M’s School of Law and the George H. W. Bush School of Government & Public Service.

“I’m pleased to be joining Texas A&M University at this exciting time of my career and their history,” offered Young. “It is a wonderful bonus, to also join my colleagues in the transformation of this law school, legal education nationally and our contributions as scholars to the continued dynamic vitality of Texas.”

“As not only a top tier, public research university, but also a land grant institution, we have a special obligation to bring the academy to the public, and these folks are going to help us expand our efforts to do that,” Dean Andy Morriss said. “We’re particularly excited to have long time bar leaders like legal ethicist Susan Fortney, former Uniform Law Commission Executive Director Bill Henning, and former American Society of International Law Executive Director Charlotte Ku joining us.”

These incoming faculty join the existing academic team, now 55 members strong and punctuated by an ethos of market-disruptive thinking and scholarship. In 2015 alone, A&M Law faculty members have gained national attention for policy papers and commentary on topics including the intersection of water and energy law, developments in intellectual property, law reform in the Middle East, and the changing face of the death penalty.

And in an era when many law schools are cutting staff and faculty as enrollments fall nationally, A&M Law has only enhanced its commitment to lead by expanding curricular options, improving student services, attracting the very best talent and aligning to Texas A&M University’s mission tenet of service to the state, nation and beyond.

One such example is a $370,000 grant awarded to the School of Law from the Access Group. With the grant, A&M Law’s Milan Markovic will serve as principal investigator of the Texas Lawyers Study, examining professional satisfaction and income levels of nearly 88,000 members of the State Bar of Texas. This study will generate an extraordinary amount of data on the economics of the legal profession and the working lives of lawyers that can inform the decision-making of prospective law students and lawyers.

“We’re proud of our work to date, and are inviting all to see how far we’ve come and to take a look at where we are heading,” Morriss said. “By attracting new talent to compliment our strong foundation of scholars, A&M Law is leading by example.”

https://law.tamu.edu

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Meet us at IFA in Basel next week?

Posted by William Byrnes on August 26, 2015


Dr. Andrew Morriss (Dean, Texas A&M & international tax economist) and I look forward toLogo_IFA_Basel_2015meeting other academics and professionals at international tax 69th IFA Congress held in the city of Basel  from Sunday, August 30 to Thursday, September 3.

Email me so that we can link up at the Congress.

The International Fiscal Association (IFA) was established in 1938 with its headquarters in the Netherlands. It is the only non-governmental and non-sectoral international organisation dealing with fiscal matters.   12,000+ government officials, MNE counsel, senior partners, and academics from 111 countries.

Its objects are the study and advancement of international and comparative law in regard to public finance, specifically international and comparative fiscal law and the financial and economic aspects of taxation.

STUDY 1:  TAX INCENTIVES ON RESEARCH AND DEVELOPMENT (R&D)

STUDY 2: PRACTICAL PROTECTION OF TAXPAYERS’ FUNDAMENTAL RIGHTS

SEMINAR A: “PATENT BOXES”

SEMINAR B: THE TAXATION OF EXPATRIATES

SEMINAR C: CROSS-BORDER SUPPLY OF SERVICES AND VAT/GST: DEVELOPMENT OF IFA PROPOSALS

SEMINAR D: PRACTICAL PROTECTION OF TAXPAYERS IN THE EXCHANGE OF INFORMATION PROCESS

SEMINAR E: CROSS-BORDER MERGERS OF COMPANIES

SEMINAR F: IFA/EU: “STATE AID REVIEW AS A MEANS TO COMBAT AGGRESSIVE TAX PLANNING”

SEMINAR G: IFA/OECD

SEMINAR H: THE TAXATION OF GLOBAL FAMILIES

SEMINAR I: EFFECTIVENESS OF PARTICIPATION EXEMPTION

SEMINAR J: RECENT DEVELOPMENTS IN INTERNATIONAL TAXATION

SEMINAR K: PRACTICAL PROTECTION OF TAXPAYERS IN THE TAX LITIGATION PROCESS

SEMINAR L: TIMING ISSUES IN THE APPLICATION OF TAX TREATIES

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Aggie Law’s orientation week wraps up

Posted by William Byrnes on August 25, 2015


12th Man SIgned Tshirt

Aggie Law’s orientation week just wrapped up – and mine as well as one of the 11 new Texas A&M law faculty.  The Dean, Andy Morriss, hosted an incoming Aggie BBQ – and Texas BBQ is good BBQ.

139 new Texas Aggies hailing from more than 60 universities, already greeting me in the ‘Howdy’ tradition at every turn.  Friendliest folk – not a whippersnapper among them.

I’m looking forward to engaging with Aggie diversity – one-fifth the first member of the family to graduate from college, quarter ethnically diverse, and majority female.

Just watched the Aggie incoming student interviews.  Quotes like “Aggie land is home”, “I feel like I could walk up to anyone and start a conversation with them” and “It’s like a big family here” – think I am going to fit in.

Especially after my first Aggie football game – against the Arkansas Razorbacks – Sept 26th.

Howdy Aggie 1Ls and GigEm!

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Dr. Jack Manhire Departs IRS & Treasury for Texas A&M Law School

Posted by William Byrnes on July 30, 2015


Dr. John T. (“Jack”) Manhire, Jr., former Chief of Legal Analysis for the IRS Office of Professional Treasury-Dept.-Seal-of-the-IRS
Responsibility and National Program Chair, Executive Education for the U.S. Treasury Executive Institute, has accepted a position as Director of Program Development at Texas A&M University School of Law.

Last month Texas A & M announced that William H. Byrnes, IV, (co-editor of our International Financial Law Prof Blog) left Thomas Jefferson Law School and joined the faculty of Texas A&M Law.

Including Dr. Manhire and the new University President, Dr. Michael Young, Texas A&M Law has hired 13 significant faculty hires for 2015, and two significant faculty visitors for Spring 2016 through the Texas A&M Institute of Advanced Studies.

For 2016, the law school is seeking to hire several more equally distinguished law professors.  See he previous post  Texas A&M University School of Law 2016-17 Faculty Recruitment Areas of Interest

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Texas A&M University School of Law Hiring Multiple New Faculty in 2016

Posted by William Byrnes on July 23, 2015


see full announcement at International Financial Law Prof Blog.

In 2015, Texas A&M University School of Law hired 11 new faculty members (12 if counting Texas A&M University’s new President, Dr. Michael Young, who is a member of the law faculty).  Below is Texas A&M Law’s announcement for faculty recruitment for the 2016-17 academic year.

TEXAS A&M UNIVERSITY SCHOOL OF LAW seeks to expand its academic program and its strong commitment to scholarship by hiring multiple exceptional faculty candidates:

1)    Candidates who are interested in building synergies with Texas A&M University’s Mays Business School, with an emphasis on scholars engaged in international business law who focus on cross-border transactions, trade, and economic law (finance, investments, dispute resolution, etc.);

2)    Candidates who are interested in building synergies with the broad mission of Texas A&M University’s College of Agricultural and Life Sciences, which include but are not limited to scholars engaged in agricultural law (including regulatory issues surrounding agriculture), rural law, community development law, food law, ecosystem sciences, and forensic evidence; and

3)    Visionary leaders in experiential education interested in guiding our existing Intellectual Property and Technology Law Clinic (with concentrations in both trademarks and patents), Entrepreneurship Law Clinic, Family Law and Benefits Clinic, Employment Mediation Clinic, Wills & Estates Clinic, Innocence Clinic, Externship Program, Equal Justice/Pro Bono Program, and Advocacy Program, with a particular emphasis on candidates who may have an interest in participating in our Intellectual Property and Technology Law Clinic or developing an Immigration Law Clinic.

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ABA task force’s reform of legal education !

Posted by William Byrnes on June 22, 2015


see the reforms at International Financial Law Prof Blog

 

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TaxProf Blog: William Byrnes Leaves Thomas Jefferson For Texas A&M

Posted by William Byrnes on June 18, 2015


TaxProf Blog: William Byrnes Leaves Thomas Jefferson For Texas A&M.

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Texas A&M School of Law Adds 12 New Faculty, Expands IP Program

Posted by William Byrnes on June 12, 2015


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Fulbright Awards and Fellowships for Law – Deadline August 3

Posted by William Byrnes on May 26, 2015


With over 80 Fulbright awards  available in countries around the globe for U.S. law professors, researchers and professionals, now is the time to refresh your thinking, and learn about law in a context other than that of the United States.  International Financial Law Prof Blog.

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Hiring Distance Education Director

Posted by William Byrnes on May 14, 2015


Texas A&M is seeking to hire a distance education full time position to execute upon and manage such programs.  Please refe Texas r any potentially interested distance education persons to the Texas A&M link:   https://jobpath.tamu.edu/postings/83039

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TJSL Ranks #13 in the Nation for Top Graduate Program | Thomas Jefferson School of Law

Posted by William Byrnes on May 1, 2015


TJSL Ranks #13 in the Nation for Top Graduate Program | Thomas Jefferson School of Law.

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Texas A&M hires 9 new law faculty

Posted by William Byrnes on April 13, 2015


http://lawprofessors.typepad.com/intfinlaw/2015/04/texas-am-hires-nine-highly-published-law-faculty.html

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Distance Learning Faculty Enrichment Discussion at University of Arizona College of Law Tomorrow

Posted by William Byrnes on April 8, 2015


University of Arizona James E. Rogers College of Law will host a faculty enrichment presentation tomorrow April 9 from 12 noon (room 237) (PPT –> Arizona WGDE 4-9-15 Final).

“I will introduce the topic with various empirical studies of distance learning pedagogy and outcomes, before turning teaching phototo the findings of the Work Group of Distance Learning for Legal Education’s Best Practice Recommendations for Distance Learning for Legal Education 2.0,” stated William Byrnes.  “The Work Group is an evolving project of faculty and administrators participating from approximately 83 ABA law schools, representative of the four tiers, and its Recommendations are collaboratively developed and authored over a four year period.”

“In 2014 the American Bar Association revised Standard 306 “Distance Education”, expanding opportunities and flexibility for institutions to leverage technological advances within the JD academic curriculum.” explained Byrnes. “The ABA initially acquiesced to an online LL.M. in 1998.  Yet, it is since the initial inception of the Work Group in 2010 that most of the 48 LL.M.s offered online by 30 ABA full approved law schools have been founded.” Byrnes exclaimed, “One ABA law school, William Mitchell, even received a variance to offer a hybrid, partially residential / partially online, JD.  It matriculated 85 candidates in its pioneer class, at its normal LSAT range.”

“As of 2015, nearly all ABA law schools offer the opportunity for an academic experience at a distance for J.D. students,” concluded Byrnes. “But many are still not leveraging communication technologies to enhance that experience and to assist with producing better learning outcomes”.

previous remarks available at Alternative Methods of Teaching and the Effectiveness of Distance Learning for Legal Education

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Distance Learning for Legal Education March 12-14 (Thursday – Saturday) in San Fran

Posted by William Byrnes on March 4, 2015


Register without delay (and without cost) for the Distance Learning for Legal Education workgroup next week (March 12-14, Thursday – Saturday) in exciting San Fran.

Ashley Dymond (Hastings) and Gary Heald (Georgetown) have accomplished an extraordinary job of designing the agenda, graciously hosted by Hastings College of Law in San Fran.  This is the Work Group’s 8th gathering as a distinct workgroup since 2011, and 14th including 2010’s Future Eds and AALS.

Why should a Dean approve a travel budget for this workgroup?  The American Bar Association initially acquiesced to an online LL.M. in 1998.  Yet, it is since the initial inception of the Work Group in 2010 that most of the 47 LL.M.s offered online by 29 ABA full approved law schools have been founded.  As of 2015, a majority of ABA law schools offer the opportunity for an online academic experience for J.D. students.  One ABA law school has received a variance to offer a hybrid, partially residential / partially online, JD.

Who attends?  Deans, Administrators, and Faculty from at least 83 ABA law schools and other stakeholders, such as foreign and U.S. academic institutions, publishers, and technology companies, have attended.  Normally between 50 – 75 per workshop, and 100 for the AALS breakfasts.

What is the deliverable for a Dean?  Guaranteed, collaborative engagement in discussions, writing, and editing that create the attached Work Group’s recommendations.  These best practice recommendations have been designed to adoptable by institutions and stakeholders through their adaptability and will form a component of a Distance Education policy. Everyone becomes a contributor, hence the name “work group”.  Attendees become the leader of the distance education pedagogical and policy discussions at home institutions.

There is no fee – but the host Hastings needs an RSVP for food and beverage.  Thus, please register by Thursday March 5th for the headcount – everything you need to know about location, transportation, accommodation is on the website.

Effectiveness of Distance Learning for Legal Educationhttp://ssrn.com/author=339796 

Much obliged for you to share this workshop with your colleagues – William Byrnes

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Two Powerhouses Announce Joint International Tax LLM

Posted by William Byrnes on January 27, 2015


Logo Starting September 2015, University of Amsterdam will offer an Advanced LL.M. of International Taxation in English, limited to just 25 annual candidates from around the world.  Applications for one of these seats are open until April.

Renown international tax academic and lawyer Dr. Dennis Weber shared with the Financial Law Prof: “The Advanced LL.M. of International Tax Lawis a full-time, one-year program.  The curriculum covers both the established framework of international tax law and emerging issues. A fundamental premise is that a proper understanding of this area of the law requires studying both the “big picture” and the technicalities.”

Weber-dennis-hoogleraar-fdr-fotograaf-gerth-van-roden-web“Moreover”, he continued, “the OECD BEPS project is on every tax counsel’s mind, and such discussions normally involve The Netherlands because, as a business friendly jurisdiction for fifty years, it has attracted multinational operations, employment and tax revenue using a ‘carrot’ policy.  Other countries are competing for multinationals’ operations, employment and tax revenue with a ‘stick’ policy of imposing high compliance costs to dissuade international activities.  The next five years will be an interesting time as the G20 goes head to head to try to peel away these operations and tax revenue from each other.”

“The IBFD is very excited about joining forces with the University of Amsterdam to create an LLM with a teaching programme that is based firmly on the research activities of both institutions and offers a combined theoretical and practical analysis of international tax law.” elaborated Prof. Dr Pasquale Pistone, Chair of the IBFD’s Academic Committee.

“There has never been a more exciting time to study international tax law than now” continued Dr. Joanna Wheeler, “the topic is firmly on the public agenda and you can see the whole field developing before your eyes just by reading the news.”

“I am delighted that the longstanding relationship between the UvA and IBFD has resulted in such a promising LLM programme, a programme that takes a holistic and policy-oriented view to taxation and that perfectly fits the current era.” said Prof. Dr Stef van Weeghel.  Dr. Weber added, “Studying international tax law in one of the most relaxed cities in the world: a perfect combination.”

Prof. William Byrnes iterated “Dr. Dennis Weber has developed a game changer in Europe with his international tax program, combining the academic quality of University of Amsterdam with the industry reputation of the IBFD.”

Learn more about international students studying in Amsterdam via YouTube

 

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Welcome this week from University of Amsterdam Centre for Tax Law

Posted by William Byrnes on January 19, 2015


Logo_uva1 Welcome from Amsterdam !  Each year the Amsterdam Centre for Tax Law (of the University of Amsterdam Law Faculty) organizes its Winter Course on International Tax Law.

This year theme is “Tax treaty application“.  The Winter Course on International Tax Law focuses on the practical problems of tax treaty application. It aims at bringing the participants’ knowledge up-to-date with recent OECD developments, major issues on tax treaty interpretation, as well as relevant case-law on tax treaties around the world.

Prof. Dennis Weber, Director of the ACTL,  has assembled a leading program faculty including Prof. Peter Watel(UvA) (who lectured me at a UvA tax student 23 year ago); Prof. Hein Vermeulen (UvA/PwC);  Prof. Stef van Weeghel (UvA/PwC); Prof. Bruno De Silva (UvA); Prof. Otto Marres (UvA/KPMG); Prof. Joanna Wheeler(IBFD/UvA); Jasper Arendse (Directorate of International Affairs Dutch Ministry of Finance); Melinda Brown (OECD); and myself, Prof. William Byrnes.

My topic examines the protocols, mechanisms and expanding scope of information exchange via bilateral and multilateral agreements.  FATCA, OECD CRS and Global Initiatives, EU Expanded Savings Directive EOI, TIEAs fall within this topic, as well as tax certification forms and validation, data collection, discernment and distribution.

The Amsterdam Centre for Tax Law (ACTL) is the tax law research centre of the University of Amsterdam. ACTL members conduct research into various subjects of tax law, with a strong emphasis on Corporate Taxation, International Tax Law and European Tax Law.

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$2 Billion Available for 2015 International Educational Exchange in Federal Appropriations

Posted by William Byrnes on January 8, 2015


read about it at International Financial Law Prof Blog.

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Highly Recommended Persuasion/Soft Skills Training

Posted by William Byrnes on November 5, 2014


My long time friend and colleague, Ross Jeffries is holding a soft skills/persuasion training in Los Angeles, January 23, 24 and 25th that I urge you to attend.

I first met Ross over 7 years ago; I had heard his name mentioned in many events on the subject and had a look at this work.  I was so impressed I actually went to the effort of paying for an event where he was guest speaking, just so I could meet him.  I can say this without hesitation: he knows more about persuasion and how language can move people’s emotions, decisions and actions that anyone else I have ever met.

As you know, getting your message across(whether in print or in person) and changing minds is a major and important part of a career in law, especially if your focus is business.

If you are a student and want to enroll, or just find out more, go here:  http://www.persuasionmastercamp.com/tjstudent/ Student enrollment is limited to 10 people.

If you are an alumni, go here: http://www.persuasionmastercamp.com. Use the code JEFFERSON and receive a 20% discount on the event.  Room seating is limited to 100 people, and his trainings are quite interactive.

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Learn About the Federal Tax System

Posted by William Byrnes on October 6, 2014


IRS logo

Want to learn about the federal tax system?  

Did you know there’s a free, online program to help teachers and students learn the “hows” and “whys” of taxes? The IRS calls it “Understanding Taxes.” It was designed by the IRS and teachers to make learning about federal taxes as easy as A-B-C.

  • Accessible (web-based)
  • Brings learning to life
  • Comprehensive

Here are six more reasons to check out the Understanding Taxes program:

1. There are thirty-nine easy, relevant and fun lessons available 24/7.

2. A student can quickly look through the program and skip around.

3. A series of tax tutorials guides through the basics of tax preparation.  Another feature is a chance to test knowledge through tax trivia. There’s also a glossary of tax terms.

4. Teachers can customize the interactive program.  It’s easy to add to a school’s curriculum.

5. No need to register or login to use the program.

6. The program is a great way to learn about the history and theory of taxes in the USA.

IRS YouTube Videos:

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White Paper – Alternative Methods of Teaching and the Effectiveness of Distance Learning for Legal Education

Posted by William Byrnes on August 26, 2014


Professor William Byrnes, Associate Dean for Graduate and Distance Education Programs at Thomas Jefferson School of Law, released remarks in the form of a white paper about teaching photodistance education methodologies called Alternative Methods of Teaching and The Effectiveness of Distance Learning For Legal Education.  The white paper makes the case for combining traditional classroom learning with online education because it is cost effective, accessible, flexible, and addresses the biggest criticism of legal education today, the lack of law school graduates who can think and practice law.  The white paper covers such topics as –

  • U.S. Department of Education’s Review of the Effectiveness of Distance Learning
  • Developing Learning Outcomes
  • Occupational Outcomes Framing Learning Outcomes
  • Information Acquisition
  • Information Delivery
  • Learning Communities
  • Learning Media
  • Learner Motivation
  • Knowledge Acquisition
  • Learning Tools

In his white paper, Professor Byrnes argues that a challenge for institutions and faculty for the pedagogical development of distance learning is to facilitate deep learning and understanding through the creation of learning materials and opportunities for various learning experiences.

in officeProfessor Byrnes explains, “The goal is to implement best practices in law schools across the country to the benefit of our esteemed institutions, our law students and the legal system at large.”  To this end, he is a primary driver of the invitation-only Work Group for Distance Learning in Legal Education that will finalize its Best Practice Report at its 10th development meeting (see https://www.eventbrite.com/e/working-group-for-distance-learning-in-legal-education-fall-2014-meeting-registration-12051364957).

White Paper: Byrnes, William H., Alternative Methods of Teaching and the Effectiveness of Distance Learning for Legal Education (August 27, 2014). Available at SSRN: http://ssrn.com/abstract=2487679

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Online Legal Education – Developing a Program or Course

Posted by William Byrnes on August 8, 2014


A Review of the Development of an Internet Delivered LL.M Program in the United States

The article comprises four sections. Part 1 addresses the economics reasons for, and logistics considerations of, the Internet-delivered Program. Part 2 reviews the pedagogical in officeapproach to legal education employed in the United States, criticisms thereof, and finally examines an emerging pedagogical trend in the United Kingdom. Part 3 reviews the teaching tools employed in the Program, and Part 4 reviews the practical aspects of developing the Program and obtaining American Bar Association (ABA) acquiescence, and reviews the Internet-delivered law courses that came before it. Finally, the article concludes with some personal observations.

The Decision Process …

Before making the decision to offer an Internet delivered Masters of Law program, integration of the Internet with legal education must be a matter of strategic thinking by the Faculty and Administration. A law school should consider several issues in its decision to pursue integration between legal education and the Internet. From a pedagogical perspective (addressed in Part 2 below), a law school’s faculty may determine a need to provide a complementary methodology for its legal teaching methods. Collaterally, the law school may want to stay in the academic and technology forefront relative to competitor law schools. The law school may also want to maintain or increase the student body size beyond the law school’s geographical boundary.

teaching photoReasons for this cause may be financial in light of local competition or a decrease in the local student market. Alternatively, it may be pedagogical, i.e; to increase student diversity, including the intake of foreign students. The law school may need to expand, for niche subjects, a class or program’s size beyond the law school’s geographical boundary for reasons of the course or program’s financial viability or student diversity. The law school should also consider whether law school’s mission may require providing legal education to geographical areas without law schools or to persons without access to local legal education, for example, economically disadvantaged persons.

After deciding whether to pursue Internet delivered legal education, the institution must then address its position regarding the pedagogy of legal education via the Internet.  The faculty discussion will likely produce heated debate between the monastic school traditionalists and the technological pioneers. Finally, the institution must address the issue of potential Internet integration while maintaining compliance with the: … read the 47 page at SSRN

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Reinventing the Legal Industry: Airbnb Hosts San Francisco LegalTech Startup Weekend

Posted by William Byrnes on August 7, 2014


First legal vertical Startup Weekend to disrupt legal industry by creating actionable solutions to intractable problems

San Francisco, Calif – August 15, 2014 – Registration is ongoing for the first legal technology Startup eventvertical Startup Weekend, set to take place from August 15-17 at Airbnb HQ in San Francisco. The LegalTech Startup Weekend organizing team invites everyone passionate about law, design, policy, data analytics, information architecture and building elegant solutions to join this weekend of innovation.

Why legal technology?

This potential for meaningful impact – and profit – is also attracting investors to the legal tech space, with investments leaping to $458 million from $66 million in 2012. The average valuation of legal tech companies currently stands at $4.2 million, and analysts expect continued exponential growth.

The intersection of law and technology presents unique challenges and exciting opportunities for growth and creativity for developers, designers, and legal industry insiders. Recent years have seen a surge of answers to law’s need for innovation: e-discovery tools, contract generation apps, law practice management SaaS, virtual firms, and websites are beginning to radically change the way lawyers research, consult and provide legal services. A wide range of possibilities remain for new startups to join companies like LegalZoom and Clio in integrating tech into solutions for consumers, attorneys, businesses, and the government.

Sign up on Eventbrite & check us out on Twitter and Facebook.  For more information, email the organizing team at legalsf@startupweekend.org.

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William Byrnes presents at LATAM International Tax Congress | Thomas Jefferson School of Law

Posted by William Byrnes on June 18, 2014


William Byrnes presents at LATAM International Tax Congress | Thomas Jefferson School of Law.

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Webcast Today at 11AM Pacific: Building a Retirement Plan: Is the Roth IRA Still A Viable Vehicle – and if Not, What Is?

Posted by William Byrnes on June 12, 2014


Complimentary Webcast today!!!

Building a Retirement Plan: Is the Roth IRA Still A Viable Vehicle – and if Not, What Is?

Professor William H. Byrnes, Associate Dean, International Tax & Financial Services, Thomas Jefferson School of Law

Bruce Guillemette, Vice President, Advanced Markets Case Design, AXA Equitable Life Insurance Company

Bill Coffin, Group Editorial Director, National Underwriter Life & Health

http://www.lifehealthpro.com/webseminars/building-a-retirement-plan-is-the-roth-ira-still-a

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International Tax Law degree – interactive online – LL.M. or Ph.D. level

Posted by William Byrnes on May 12, 2014


If you are interested in discussing the online Master or Doctoral degree in international taxation and financial services, then please fill out the request for an appointment below and comment whether you prefer Skype-Video or Google Video-Hangout (or just a phone call).  My office at the law school in San Diego is (619) 961-4211 or add me on Skype “professorbyrnes”. My Google Hangouts is email: profbyrnes@gmail.com

Meet a couple PhD Alumni Google-YouTube webinar of May 7, 2014: http://youtu.be/ho2Qn3KpzqE

Meet Alumni webinar: http://mastersinlaw.tjsl.edu/news-resouces/recorded-webinars/webinar-03-31-2011/

Meet Alumni webinar: http://mastersinlaw.tjsl.edu/news-resouces/recorded-webinars/webinar-06-29-2011/

Meet Alumni webinar: http://mastersinlaw.tjsl.edu/news-resouces/recorded-webinars/webinar-02-28-2012/

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