William Byrnes' Tax, Wealth, and Risk Intelligence

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

International Tax Training

“Texas A&M University is among the pioneers of change in tax education.” – Ernst & Young’s Tax Insights Magazine (2016)

“The central function of the tax office has evolved from strategy and planning into risk management enabled by technology”, says Professor William Byrnes. “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) as well as the European Union.” 

Drop me a line
williambyrnes@tamu.edu

Let’s hang out

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 20 students 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 of some case study presentations 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 initiated the original version of this international tax program in 1994. Join his network of 29,000+ on LinkedIn 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, 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!

International Tax Risk Management curriculum

FALL 2020 (Aug 23 through Nov 23) each course is 3 academic credits

International Tax Risk Management & Domestic Systems (inbound) (meet Tuesdays and Sundays at 8am Central Daylight Dallas time zone)

International Tax Risk Management II (Data, Analytics & Technology) 3 credits (meet Tuesdays and Sundays at 8am Central Daylight Dallas time zone)

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 24 Domestic Tax Rights; Double Taxation; Tax Treaty Allocation Of Tax Rights
  • Week 2 Aug 31 Types Of Taxes; Tax Treaty Interpretation
  • Week 3: Sept 7 Tax Jurisdiction Over Persons, Tax Treaty Interpretation
  • Week 4: Sept 14 Tax Jurisdiction of Corporations; Tax Treaty Interpretation & Application
  • Week 5: Sept 21 Tax Jurisdiction of Entities
  • Week 6: Sept 28 CFC regimes (e.g. Subpart F, GILTI, Lists, Pillar II)

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 12 Tax of Business Income (PE, Nexus)
  • Week 2 Oct 19 Tax of Investment Income
  • Week 3: Oct 26 Taxation of Services and Employment Income (including DST)
  • Week 4: Nov 2 Double Taxation and Tax Credits
  • Week 5: Nov 9 Tax Accounting
  • Week 6: Nov 16 Introduction to Management of Tax and Data
  • Capstone Nov 24: Groups Create Client Case Studies

SPRING 2021 (Jan 19 – April 30)

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

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

  • 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 material professor)

  • 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 material professor)

SUMMER 2020 (May 18 through June 30)

FATCA, CRS, and AEoI (Law, Data, Systems): 3 credits (meet 8:00am Monday and Thursday Central Daylight Dallas time zone) 

  • 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)
  • 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)
  • Week 5. June 14: FATCA IGAs & CRS Risk Management Melissa Muhammad melissamuhammadesq@gmail.com
  • Week 6. June 21: Financial Institutions Systems And Data: Haydon Perryman (Bank of America, UBS, Barclays, RBS and Lloyds)
  • Week 7 June 28 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 at 8am and Sunday at 9:30am Central Daylight Dallas time zone) 

Managing VAT, Customs, and Duties Risk: 3 credits (meet 8:00am Monday and Thursday Central Daylight Dallas time zone) 

  • Week 1. May 18: VAT Compliance Risk Matrix Hafiz Choudhury
  • Week 2. May 25: VAT Compliance Risk Matrix Hafiz Choudhury
  • Week 3. June 1: VAT – Dr. Santiago Ibañez Marcilla
  • Week 4. June 8: Customs & Duties EU Commission director for Customs Dr. Santiago Ibañez Marcilla
  • Week 5. June 15: Customs & Duties developing country focused person
  • Week 6. June 23: Customs & Duties developing country focused person
  • Week 7 capstone for all Summer courses: “Tax Technology and the future of Tax Departments”Dr. Debora Correa Talutto

International Tax Risk Management III (Planning) 3 credits (meet Tuesday at 8am and Sunday at 9:30am Central Daylight Dallas time zone) 

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