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LexisNexis Publishes William H. Byrnes “International Withholding Tax Treaty Guide – 2nd Edition”

Posted by William Byrnes on October 24, 2013


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LexisNexis released in September 2013 the new and expanded 2nd Edition of its International Withholding Tax Treaty Guide.  Thomas Jefferson’s Associate Dean of Graduate & Distance Education William Byrnes is the co-author with Dr. Robert J. Munro, retired law librarian of University of Florida. This is William Byrnes and Robert Munro’s sixth book together.

When asked about how Dr. Munro and he started writing together, William Byrnes replied: “When I met him in 1998, Dr. Robert Munro was Co-Director of the Center for International Financial Crimes Studies at University of Florida’s College of Law, focusing on anti money laundering and anti terrorism financing, whereas I focused on international taxation and multinational behavior.  We explored several overlapping areas of interest, approaching each from our very different perspectives.  Dr. Munro brings to the table his experience as a national security expert and his research into undocumented marketplaces whereas I bring my experience with multinational organization decision making and risk management.”

“Dr. Munro, after retiring from University of Florida, actively teaches anti money laundering for the Thomas Jefferson graduate program and provides its graduate and juris doctorate students with publication opportunities through the publication course to promote their professional careers.  He has been particularly helpful with assisting students seek national security careers.”

Regarding the 2nd edition International Withholding Tax Treaty Guide published this month, Robert Munro added: “The second edition of International Withholding Tax Treaty Guide includes a new binder with new chapter structures of completely rewritten tax information and analysis.  The International Withholding Tax Treaty Guide has been expanded to include many new countries to match the robust list of 110 countries of Foreign Tax & Trade Briefs.  Moreover, International Withholding Tax Treaty Guide subscribers will receive new chapters of analysis and planning based on the OECD Model DTA articles and major trading country jurisprudence that are most relevant to corporate tax counsel, addressing topics such as capital gains, dividends, interest, rents, leasing income, royalties, and permanent establishment.  Corporate counsel may combine the Foreign Tax & Trade Brief publications with Tax Havens of the World to form an international tax planning and risk management library at substantially less cost than competitive product suites.”

William Byrnes explained the history of this Lexis publication: “During the Second World War, Walter H. Diamond, then a banker, was tasked by the federal government to analyze and report on the investment and tax laws of each country and territory of which the Allies held confiscated Axis assets.  Walter Diamond ventured though out the continents and Pacific meticulously collecting the local tax and investment laws and regulations applicable to the Allies new assets, and transcribed them into an understandable brief by country for the U.S. Treasury.  In 1948, Matthew Bender published his country briefs in the first edition of Foreign Tax & Trade Briefs.  Since 1948, the quarterly updated country briefs have been leveraged by thousands of multinational corporate counsel subscribers as part of their foreign tax and investments risk management best practices.”

“In 1974, Matthew Bender added a third binder to Foreign Tax & Trade Briefs, International Withholding Tax Treaty Guide, to specifically address the important role of tax treaties in tax risk management that had developed in the sixties.  By 1975, nearly 1,000 tax treaties had been signed between countries based on the OECD’s Model with an additional 200 treaties in force based on the League of Nations Models.  There are now more than 3,200 tax related treaties.”

When asked their next project together, Dr. Munro stated: “We are looking at tackling the rewrite of all three binders of Lexis’ Tax Havens of the World, with a new table of contents, new chapters, and a more modern ‘post-OECD reports’ approach.”  William Byrnes added, “Yes, this major re-do should keep us creatively busy another couple years.”

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Second Edition of Lexis’ International Withholding Tax Treaty Guide released

Posted by William Byrnes on August 26, 2013


Associate Dean William Byrnes is also pleased to announce the publication of International Withholding Tax Treaty Guide, Second Edition by LexisNexis.

The second edition of International Withholding Tax Treaty Guide, authored by Professor William H. Byrnes and Dr. Robert J. Munro, includes new binders with new chapter structures of completely rewritten tax information and analysis. The second edition of Foreign Tax & Trade Briefs includes a new structure for all 110 country chapters to reflect the evolution of national tax systems since 1948. The International Withholding Tax Treaty Guide has been expanded to include many new countries to match the robust list of Foreign Tax & Trade Briefs, and its footnote numbering has been amended for brevity and modern coherence.

Moreover, International Withholding Tax Treaty Guide subscribers will receive new chapters of analysis and planning based on the OECD Model DTA articles and major trading country jurisprudence that are most relevant to corporate tax counsel, addressing topics such as capital gains, dividends, interest, rents, leasing income, royalties, and permanent establishment, as well as developing topics such as new standards of information exchange. Corporate counsel may combine these publications with the LexisNexis Matthew Bender publication Tax Havens of the World to form a complete international tax planning and risk management library.

Associate Dean William Byrnes said “The Second Edition completes my re-write process of this book to re-structure the citation architecture for a modern approach to tax treaty analysis,”  Over the next two years I will author an in-depth, comparative analysis of tax treaty articles, to provide practitioners and arbitrators a go-to treatise for global corporate planning.”

William Byrnes continued “In 1974, Matthew Bender added a third binder to Foreign Tax & Trade Briefs, the International Withholding Tax Treaty Guide, to specifically address the important role of tax treaties in tax risk management that had developed in the sixties. By 1975, nearly one thousand tax treaties had been signed between countries based on the OECD’s Model with an additional 200 treaties in force based on the League of Nations Models. Moreover, many (former) territories had become independent, developing countries with the ability to establish their own tax treaties. There are now more than 3,200 tax treaties, of which 2,900 are signed and in effect with the remaining 300 yet to become effective by official legislative approval.”

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