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

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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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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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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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