William Byrnes' Tax, Wealth, and Risk Intelligence

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

Posts Tagged ‘risk management’

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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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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NationalUnderwriter.com is celebrating throughout the month of December with two FREE Shipping offers! (No coupon necessary)

Posted by William Byrnes on December 12, 2013

NationalUnderwriter.com is celebrating throughout the month of December with two FREE Shipping offers! (No coupon necessary; links provided below.)  Also, in preparing for the new year, NationalUnderwriter.com has the book titles for January 2014 that students need!2014_tf_on_individuals_small_businesses-m_1

Now through 12/14/2013, shoppers enjoy FREE Shipping on Insurance, Finance, and Legal bookstore purchases of $100 or more at NationalUnderwriter.com!

And then, from 12/15/2013 through 12/31/2013, shoppers to enjoy FREE Shipping on any Insurance, Finance, or Legal bookstore purchase at NationalUnderwriter!

1. FREE Shipping on Insurance, Finance & Legal bookstore purchases of $100 or more through 12/14/2013 at NationalUnderwriter – ORDER NOW!

2. FREE Shipping on any Insurance, Finance, or Legal bookstore purchase from 12/15/2013 through 12/31/2013 at NationalUnderwriter – ORDER NOW!

3. “The Tools & Techniques of Investment Planning, 3rd Edition” (SKU: 2730003) IN STOCK at NationalUnderwriter – ORDER NOW!

4. “The Tools & Techniques of Estate Planning for Modern Families” (SKU: 2890000) IN STOCK at NationalUnderwriter – ORDER NOW!

5. “Principles of Estate Planning, First Edition, Updated for 2013” (SKU: 9110001B) IN STOCK at NationalUnderwriter – ORDER NOW!

6. “The Tools & Techniques of Employee Benefit and Retirement Planning, 13th Edition” (SKU: 2710013B) IN STOCK at NationalUnderwriter – ORDER NOW!

7. “The Tools & Techniques of Estate Planning, 16th Edition” (SKU: 2850016B) IN STOCK at NationalUnderwriter – ORDER NOW!

8. “The Tools & Techniques of Life Insurance Planning, 5th edition” (SKU: 2700005B) IN STOCK at NationalUnderwriter – ORDER NOW!

9. “Case Approach to Financial Planning: Bridging the Gap between Theory and Practice, 2nd Ed.” (SKU 7200002B) IN STOCK at Nat’l Underwriter – ORDER NOW!

10. “The Process of Financial Planning: Developing a Financial Plan, 2nd Edition” (SKU: 7190002B) IN STOCK at NationalUnderwriter – ORDER NOW!

11. “The Tools & Techniques of Financial Planning, 10th Edition” (SKU: 2770010B) IN STOCK at NationalUnderwriter – ORDER NOW!

12. The Tools & Techniques of Life Insurance Planning & Risk Management for Financial Planners (SKU: 8080003) IN STOCK at NationalUnderwriter – ORDER NOW!

13. “Income Tax Planning, 3rd Edition” (SKU: 2740003B) IN STOCK at NationalUnderwriter – ORDER NOW!

14. “Tools & Techniques of Risk Management & Insurance” (SKU: 2960000) IN STOCK at NationalUnderwriter – ORDER NOW!

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Reforming Annuities’ Image Problem: New Focus on Risk

Posted by William Byrnes on August 16, 2013

Today’s media coverage of the variable annuity market has focused on company buybacks and modifications to existing clients’ product guarantees—a prospect that has many clients feeling more wary than ever about annuity purchases.

Despite this, insurance companies have used the negative experiences of recent months as motivation to effect positive change in their annuity product offerings by offering clients real flexibility and risk management options.

read William Byrnes and Robert Bloink’s full analysis regarding annuities at > ThinkAdvisor <

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States Competing for Captives Insurance Business

Posted by William Byrnes on March 19, 2012

Looking to recapture its competitiveness in the domestic captive insurance business, Nevada passed Assembly Bill 74 (AB 74), which amends the state’s captive insurance law. Nevada Governor Brian Sandoval recently praised the amendment, saying it that “will make Nevada a more attractive place to do business for captive insurers.”

Generally, a captive insurance company forms as a subsidiary of a company to cover the risks of the parent company and its other subsidiaries. A captive insurance company typically does not insure risks of unrelated third parties—although some will insure their customers’ risks. Other captive insurers assume the risks of members of a trade association or group.

Read this complete analysis of the impact at AdvisorFX (sign up for a free trial subscription with full access to all of the planning libraries and client presentations if you are not already a subscriber).

For previous coverage of the application of the Health Care law to captive provided health insurance, see Tax Facts, see 252. What nondiscrimination requirements apply to employer provided health benefits?.

Questions about Captives? Contact our Panel of Experts. Benjamin Terner is our “Captive Expert” and can answer your questions relating to domestic and offshore arrangements

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modern trends surrounding captive insurance – webinar

Posted by William Byrnes on August 26, 2011

Captive Insurance webcast



Please join us next month as we discuss the modern trends surrounding captive insurance. Wealth managers who have an interest in captives will likely find the information and presentation useful. CLICK HERE TO REGISTER

For additional information on captives see, Advisorfyi.com–States Competing for Captives Insurance Business,Alternative Risk Transfer RevisitedCaptive Market Continues to GrowLLC Series and Cell CompaniesGroup Captive Insurance Companies and Year End Tax Considerations, and A Dollar Saved…Captive Insurance Company Costs


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Financial Crimes and Institutional Security

Posted by William Byrnes on March 15, 2011

Dates:  Video-conference course starting March 28 ending 10 weeks later in late May

Medium – Wimba live lectured webcam video-conference and LexisNexis blackboard course-ware

Enrollment Contact: Associate Dean William H. Byrnes – wbyrnes@tjsl.edu

or call +1 (619) 961-4211

includes access to full online international tax library of databases such as IBFD, CCH, Checkpoint, RoyaltyStat, EdgarStat, LexisNexis, Westlaw, amongst many others.

Approved for Certified Fraud Examiner (CFE) – Lead Professor: Stephen Polak (see professors link)

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Group Captive Insurance Companies and Year End Tax Considerations

Posted by William Byrnes on November 30, 2010

Assorted international currency notes.

Image via Wikipedia

As we have discussed in previous blogticles, captive insurance can be a viable method to more efficiently protect against certain risks under various circumstances.  For discussion on these topics please see our blogticles on AdvisorFYI from the week of August 30th, Monday through Wednesday, Alternative Risk Transfer BasicsRisk and Self-Insurance, andCaptive Insurance Company Introduction.

In addition, we have discussed in previous blogticles the ability to deduct prepaid expenses for certain items, both from an accrual basis and cash receipts and disbursements method taxpayer approach.  One such class of deductions that is generally allowable is, “insurance premiums against fire, storm, theft, accident, or other similar losses in the case of a business, and rental for the use of business property.”

See generally our blogticles from November entitled, Year End Tax Planning: Pre-Paid Insurance Expense For Accrual Accounting Taxpayers, and Year End Tax Planning: Pre-Paid Expenses For Cash Accounting Taxpayers.

Read this entire set of articles starting at AdvisorFYI.

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A Dollar Saved…Captive Insurance Company Costs

Posted by William Byrnes on October 12, 2010

Why is this Topic Important to Wealth Managers? Provides specific information in regards to costs relating to the formation of an insurance company.  Discusses multiple domicile options and how they relate to each other.

Wealth managers may be interested to know generally what costs are involved to form and manage a captive insurance company in different jurisdictions.  Take for example Vermont.  It is known as the “Captive Capital” here in the States, and for good reason, Vermont has licensed over 900 captives at last count.[1]

The licensing fees in Vermont total $4,800 (in the first year and only $300 a year thereafter.) [2] However, there are a couple of downsides to the preliminarily greener pastures.  First, Vermont requires initial capitalization of a “pure”, which includes a traditional single parent, captive of $250,000. [3] Secondly, Vermont requires the captive to pay minimum premium tax of $7,500 which has an underwriting level of approximately around $2 million dollars at a rate of 0.38%. [4]

As a general rule, the formation and annual expenses, including premium taxes, of captive insurance companies will be lower in most offshore jurisdictions rather than domestic domiciles.

Read on about A Dollar Saved…Captive Insurance Company Costs

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Certified International Tax Analyst

Posted by William Byrnes on May 14, 2010

Professional Designation: American Academy of Financial Management

Exam preparation: International Tax Planning & Risk Management course

Topics: Treaty Structures, Transfer Pricing, Risk Score Cards, Offshore Strategies and Compliance amongst others – taught via case studies

Delivery: 40 hours of live lecture and case studies – audio headsets for web conferencing

Start: May 24 (Monday) – end August 13 (Friday)

When: New York 11am – 12:30 pm (Eastern Time)

Recordings: all lectures are made available within 1 hour on-demand

Contact: Prof. William Byrnes, Associate Dean – wbyrnes@tjsl.edu   +1 (619) 297-9700 x 6955

Materials: tuition includes full Westlaw, Lexis, CCH, IBFD, Checkpoint, Orbitax and 20 other professional databases

Accreditation: applies toward the Legum Magister (LL.M.), Juris Scientiae Magister (J.S.M),  Scientiae Juridicae  Doctor (JSD) of Thomas Jefferson School of Law (San Diego)

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Certified Risk Manager™ (CRM)

Posted by William Byrnes on December 7, 2009

Course date: January 18th – April 9th 2010

Lectures: 42 lecture hours using webcams / headsets (see www.wimba.com) with sharing of applications – also recorded for later on-demand viewing

Online Databases & Library: full access included

Course book: online

Professional Designation: by the American Academy® (www.aafm.us)

Contact: Assoc. Dean William Byrnes  wbyrnes@tjsl.edu  (619) 374-6955

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